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    <title>2017 (12) TMI 991 - ITAT DELHI</title>
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    <description>Reassessment under section 148 issued after four years was invalid where the original scrutiny assessment had already examined the repair and maintenance claim and the assessee had disclosed the relevant facts. The reopening reasons relied only on the same material already on record and did not show any new tangible material or any recorded failure by the assessee to make full and true disclosure of material facts. On those facts, the attempted reassessment was a mere change of opinion and was unsustainable in law, so the notice was quashed and the reassessment annulled.</description>
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    <pubDate>Tue, 21 Nov 2017 00:00:00 +0530</pubDate>
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      <title>2017 (12) TMI 991 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=352722</link>
      <description>Reassessment under section 148 issued after four years was invalid where the original scrutiny assessment had already examined the repair and maintenance claim and the assessee had disclosed the relevant facts. The reopening reasons relied only on the same material already on record and did not show any new tangible material or any recorded failure by the assessee to make full and true disclosure of material facts. On those facts, the attempted reassessment was a mere change of opinion and was unsustainable in law, so the notice was quashed and the reassessment annulled.</description>
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      <pubDate>Tue, 21 Nov 2017 00:00:00 +0530</pubDate>
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