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    <title>2017 (3) TMI 110 - DELHI HIGH COURT</title>
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    <description>Reopening of an assessment under Section 148 is not sustainable where the original scrutiny assessment under Section 143(3) had already examined the same issue and the assessee had fully disclosed material facts. The assessment records showed that the nature of the business activities and the exemption claim were specifically queried, replies and supporting documents were furnished, and the reassessment was based on the same material without any fresh tangible material. A change of view on whether receipts were agricultural income or business income amounted to a mere change of opinion. The notice under Section 148 and the proceedings based on it were quashed.</description>
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    <pubDate>Tue, 07 Feb 2017 00:00:00 +0530</pubDate>
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      <title>2017 (3) TMI 110 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=339607</link>
      <description>Reopening of an assessment under Section 148 is not sustainable where the original scrutiny assessment under Section 143(3) had already examined the same issue and the assessee had fully disclosed material facts. The assessment records showed that the nature of the business activities and the exemption claim were specifically queried, replies and supporting documents were furnished, and the reassessment was based on the same material without any fresh tangible material. A change of view on whether receipts were agricultural income or business income amounted to a mere change of opinion. The notice under Section 148 and the proceedings based on it were quashed.</description>
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      <pubDate>Tue, 07 Feb 2017 00:00:00 +0530</pubDate>
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