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    <title>2016 (9) TMI 857 - GUJARAT HIGH COURT</title>
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    <description>Reassessment under section 147 was held invalid where the original scrutiny assessments had been completed under section 143(3) and the reopening relied on an audit objection and valuation material already on record. The court held that the Assessing Officer must have an independent reason to believe, supported by fresh tangible material with a live nexus to escapement of income. A completed assessment cannot be reopened on a mere change of opinion, and an audit objection cannot replace the officer&#039;s own satisfaction. Wealth-tax valuation material already considered in the original assessment could not by itself justify reopening. The issue was decided in favour of the assessee.</description>
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    <pubDate>Fri, 17 Jun 2016 00:00:00 +0530</pubDate>
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      <title>2016 (9) TMI 857 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=332596</link>
      <description>Reassessment under section 147 was held invalid where the original scrutiny assessments had been completed under section 143(3) and the reopening relied on an audit objection and valuation material already on record. The court held that the Assessing Officer must have an independent reason to believe, supported by fresh tangible material with a live nexus to escapement of income. A completed assessment cannot be reopened on a mere change of opinion, and an audit objection cannot replace the officer&#039;s own satisfaction. Wealth-tax valuation material already considered in the original assessment could not by itself justify reopening. The issue was decided in favour of the assessee.</description>
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      <pubDate>Fri, 17 Jun 2016 00:00:00 +0530</pubDate>
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