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    <title>1999 (12) TMI 879 - ITAT MUMBAI</title>
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    <description>Reopening under section 147(a) was invalid where the original assessment under section 143(3) had already examined the books and accepted the disclosed gross profit, and the only basis for reopening was seized material relating to a different, much later assessment year. Such material lacked a direct nexus with the relevant year and could not provide the requisite reason to believe that income had escaped assessment; reliance on a supposed similar method in earlier years was treated as a mere change of opinion. The reopening was therefore rightly set aside in favour of the assessee.</description>
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    <pubDate>Wed, 08 Dec 1999 00:00:00 +0530</pubDate>
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      <title>1999 (12) TMI 879 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=281685</link>
      <description>Reopening under section 147(a) was invalid where the original assessment under section 143(3) had already examined the books and accepted the disclosed gross profit, and the only basis for reopening was seized material relating to a different, much later assessment year. Such material lacked a direct nexus with the relevant year and could not provide the requisite reason to believe that income had escaped assessment; reliance on a supposed similar method in earlier years was treated as a mere change of opinion. The reopening was therefore rightly set aside in favour of the assessee.</description>
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      <pubDate>Wed, 08 Dec 1999 00:00:00 +0530</pubDate>
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