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    <description>Section 147(a) reopening was sustained because the statutory conditions for reassessment were found satisfied on the facts, making the completed assessment for the relevant year validly reopenable. Income under section 41(2) was also treated as having accrued in the assessment year 1970-71 because the amount in dispute became due when the award was made a rule of court within the previous year relevant to that assessment year. The High Court&#039;s answers on both questions were affirmed, and the Revenue succeeded.</description>
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