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    <title>2017 (3) TMI 143 - ITAT KOLKATA</title>
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    <description>Reassessment under section 147 was held invalid where the reopening relied on the same tax audit material and facts already examined in the original scrutiny assessment under section 143(3); absent new tangible material, the action amounted to a mere change of opinion, so the reassessment was annulled. The contribution to an approved superannuation fund was also treated as deductible because it was paid during the relevant previous year and fell within the provision allowing deduction on actual payment basis; it was not disallowable merely as a prior-period expense, so the disallowance was deleted.</description>
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      <title>2017 (3) TMI 143 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=339640</link>
      <description>Reassessment under section 147 was held invalid where the reopening relied on the same tax audit material and facts already examined in the original scrutiny assessment under section 143(3); absent new tangible material, the action amounted to a mere change of opinion, so the reassessment was annulled. The contribution to an approved superannuation fund was also treated as deductible because it was paid during the relevant previous year and fell within the provision allowing deduction on actual payment basis; it was not disallowable merely as a prior-period expense, so the disallowance was deleted.</description>
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      <pubDate>Wed, 01 Mar 2017 00:00:00 +0530</pubDate>
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