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    <title>2018 (6) TMI 402 - ITAT KOLKATA</title>
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    <description>The Tribunal upheld the decision of the Ld. CIT(A) to annul the assessment made by the A.O. under section 143(3) / 147 of the Income Tax Act, 1961. The reopening of the assessment was deemed invalid as it was found to be based on a mere change of opinion without any new tangible material. Consequently, the additions made by the A.O. on account of undisclosed sales and unexplained purchases were not addressed separately. The revenue&#039;s appeal was dismissed, and the order was pronounced on 30th May 2018.</description>
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      <link>https://www.taxtmi.com/caselaws?id=361575</link>
      <description>The Tribunal upheld the decision of the Ld. CIT(A) to annul the assessment made by the A.O. under section 143(3) / 147 of the Income Tax Act, 1961. The reopening of the assessment was deemed invalid as it was found to be based on a mere change of opinion without any new tangible material. Consequently, the additions made by the A.O. on account of undisclosed sales and unexplained purchases were not addressed separately. The revenue&#039;s appeal was dismissed, and the order was pronounced on 30th May 2018.</description>
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