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    <title>2017 (9) TMI 487 - GUJARAT HIGH COURT</title>
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    <description>Reassessment beyond four years from the end of the assessment year is invalid where the original scrutiny assessment had already examined the section 10B claim and the assessee had disclosed all primary facts. The Assessing Officer had queried the claim, received supporting documents, and substantially accepted it, so reopening on the same material amounted to a mere change of opinion. In the absence of any failure to fully and truly disclose material facts, the reassessment notice could not be sustained, and the reopening was held to fail in favour of the assessee.</description>
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      <description>Reassessment beyond four years from the end of the assessment year is invalid where the original scrutiny assessment had already examined the section 10B claim and the assessee had disclosed all primary facts. The Assessing Officer had queried the claim, received supporting documents, and substantially accepted it, so reopening on the same material amounted to a mere change of opinion. In the absence of any failure to fully and truly disclose material facts, the reassessment notice could not be sustained, and the reopening was held to fail in favour of the assessee.</description>
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      <pubDate>Mon, 04 Sep 2017 00:00:00 +0530</pubDate>
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