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    <title>2016 (3) TMI 418 - ITAT MUMBAI</title>
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    <description>The Tribunal dismissed the Revenue&#039;s appeal, upholding the CIT(A)&#039;s order that the reopening of the assessment was invalid as it was based on a change of opinion without any new material. The additions made by the AO were quashed, and the original assessment order was restored. The Tribunal refrained from deciding the issues on merit, as the reopening itself was held to be illegal and bad in law.</description>
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      <description>The Tribunal dismissed the Revenue&#039;s appeal, upholding the CIT(A)&#039;s order that the reopening of the assessment was invalid as it was based on a change of opinion without any new material. The additions made by the AO were quashed, and the original assessment order was restored. The Tribunal refrained from deciding the issues on merit, as the reopening itself was held to be illegal and bad in law.</description>
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