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    <title>2016 (1) TMI 942 - MADRAS HIGH COURT</title>
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    <description>HC quashed the reassessment proceedings initiated under s.147 beyond four years from the end of the relevant assessment year. It held that the assessee had made a true and full disclosure of all primary and material facts during the original scrutiny assessment. The Assessing Officer had consciously accepted the assessee&#039;s claim relating to the cash credited under s.69A. Therefore, the subsequent reopening was based only on a change of opinion, offending the proviso to s.147. The impugned reassessment and consequential addition under s.69A were set aside in favour of the assessee.</description>
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      <title>2016 (1) TMI 942 - MADRAS HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=271150</link>
      <description>HC quashed the reassessment proceedings initiated under s.147 beyond four years from the end of the relevant assessment year. It held that the assessee had made a true and full disclosure of all primary and material facts during the original scrutiny assessment. The Assessing Officer had consciously accepted the assessee&#039;s claim relating to the cash credited under s.69A. Therefore, the subsequent reopening was based only on a change of opinion, offending the proviso to s.147. The impugned reassessment and consequential addition under s.69A were set aside in favour of the assessee.</description>
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