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    <title>2008 (4) TMI 729 - DELHI HIGH COURT</title>
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    <description>A reopening notice under sections 147 and 148 was held unsustainable where the assessee had made full and complete disclosure of the relevant facts and the Assessing Officer sought to revisit material already on record. The reopening was based on section 41(4A), but the effective date and related facts had already been disclosed in the computation of income. On that basis, the appellate authorities treated the exercise as a mere change of opinion, and the reassessment challenge failed with the appeal dismissed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=177538</link>
      <description>A reopening notice under sections 147 and 148 was held unsustainable where the assessee had made full and complete disclosure of the relevant facts and the Assessing Officer sought to revisit material already on record. The reopening was based on section 41(4A), but the effective date and related facts had already been disclosed in the computation of income. On that basis, the appellate authorities treated the exercise as a mere change of opinion, and the reassessment challenge failed with the appeal dismissed.</description>
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