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    <title>2019 (1) TMI 1214 - BOMBAY HIGH COURT</title>
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    <description>The High Court upheld the Tribunal&#039;s decision to quash the reassessment proceedings initiated by the Assessing Officer under Section 147 of the Income Tax Act, 1961. The court ruled that the attempt to disallow the deduction claim during reassessment amounted to a impermissible change of opinion, as the claim had already been examined in the original assessment proceedings. The court cited the principle established in a Supreme Court case that the concept of change of opinion continues to apply post-amendment in Section 147 of the Act. The Tax Appeal was dismissed as no question of law arose from the case.</description>
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    <pubDate>Mon, 21 Jan 2019 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=374049</link>
      <description>The High Court upheld the Tribunal&#039;s decision to quash the reassessment proceedings initiated by the Assessing Officer under Section 147 of the Income Tax Act, 1961. The court ruled that the attempt to disallow the deduction claim during reassessment amounted to a impermissible change of opinion, as the claim had already been examined in the original assessment proceedings. The court cited the principle established in a Supreme Court case that the concept of change of opinion continues to apply post-amendment in Section 147 of the Act. The Tax Appeal was dismissed as no question of law arose from the case.</description>
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      <pubDate>Mon, 21 Jan 2019 00:00:00 +0530</pubDate>
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