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    <title>2019 (1) TMI 544 - BOMBAY HIGH COURT</title>
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    <description>Reassessment beyond four years after a scrutiny assessment requires the assessee&#039;s failure to disclose fully and truly all material facts. Where offshore support operations, vessels, charter arrangements and tonnage-tax eligibility were disclosed and examined during the original assessment, a later view on eligibility does not establish nondisclosure. Reopening also cannot rest on a change of opinion when the Assessing Officer had specifically examined the relevant business activities and tax treatment and no fresh tangible material emerged. The reopening notice was therefore quashed, and the petition succeeded.</description>
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      <description>Reassessment beyond four years after a scrutiny assessment requires the assessee&#039;s failure to disclose fully and truly all material facts. Where offshore support operations, vessels, charter arrangements and tonnage-tax eligibility were disclosed and examined during the original assessment, a later view on eligibility does not establish nondisclosure. Reopening also cannot rest on a change of opinion when the Assessing Officer had specifically examined the relevant business activities and tax treatment and no fresh tangible material emerged. The reopening notice was therefore quashed, and the petition succeeded.</description>
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