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    <title>2007 (10) TMI 657 - ITAT CHENNAI</title>
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    <description>The Tribunal held that the reassessment beyond the time limit specified in the proviso to section 147 of the Income Tax Act was illegal as it was based on a change of opinion, not on new undisclosed facts. Consequently, the reassessment proceedings were annulled, and the order of the CIT(A) was set aside. The appeal by the assessee was allowed, while the appeal by the Revenue was dismissed.</description>
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      <description>The Tribunal held that the reassessment beyond the time limit specified in the proviso to section 147 of the Income Tax Act was illegal as it was based on a change of opinion, not on new undisclosed facts. Consequently, the reassessment proceedings were annulled, and the order of the CIT(A) was set aside. The appeal by the assessee was allowed, while the appeal by the Revenue was dismissed.</description>
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