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    <title>2012 (11) TMI 1087 - ITAT DELHI</title>
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    <description>The Tribunal held that the reassessment proceedings initiated under section 147 r.w. 148 after four years from the end of the assessment year were invalid. The reassessment was deemed improper as it was based on already disclosed materials and lacked fresh evidence. The Tribunal emphasized that the reassessment could not be solely due to a change of opinion and required the assessee&#039;s failure to fully disclose material facts. Consequently, the Rs. 55,15,000/- addition on account of income from undisclosed sources was deleted, and the Revenue&#039;s appeal was dismissed.</description>
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    <pubDate>Fri, 09 Nov 2012 00:00:00 +0530</pubDate>
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      <title>2012 (11) TMI 1087 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=174189</link>
      <description>The Tribunal held that the reassessment proceedings initiated under section 147 r.w. 148 after four years from the end of the assessment year were invalid. The reassessment was deemed improper as it was based on already disclosed materials and lacked fresh evidence. The Tribunal emphasized that the reassessment could not be solely due to a change of opinion and required the assessee&#039;s failure to fully disclose material facts. Consequently, the Rs. 55,15,000/- addition on account of income from undisclosed sources was deleted, and the Revenue&#039;s appeal was dismissed.</description>
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      <pubDate>Fri, 09 Nov 2012 00:00:00 +0530</pubDate>
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