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    <title>2017 (5) TMI 685 - GUJARAT HIGH COURT</title>
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    <description>Reopening of assessment beyond four years requires a failure by the assessee to disclose fully and truly all material facts necessary for assessment; where relevant particulars were disclosed and the scrutiny assessment had already examined the claims, the jurisdictional was not met. A completed scrutiny assessment also cannot be reopened on a mere change of opinion when the same issues were specifically queried, replied to, and accepted or disallowed in the original assessment. On these facts, the notice under Section 148 and the reassessment proceedings were quashed.</description>
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      <description>Reopening of assessment beyond four years requires a failure by the assessee to disclose fully and truly all material facts necessary for assessment; where relevant particulars were disclosed and the scrutiny assessment had already examined the claims, the jurisdictional was not met. A completed scrutiny assessment also cannot be reopened on a mere change of opinion when the same issues were specifically queried, replied to, and accepted or disallowed in the original assessment. On these facts, the notice under Section 148 and the reassessment proceedings were quashed.</description>
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