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    <title>2019 (8) TMI 985 - ITAT PUNE</title>
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    <description>The Tribunal upheld the decision of the Commissioner of Income Tax (Appeals) and dismissed the Revenue&#039;s appeal regarding the reopening of assessment for the assessment year 2007-08. It was found that the reassessment beyond the four-year period was not justified as it was based on a change of opinion by the Assessing Officer rather than any failure on the Assessee&#039;s part to disclose material facts. The Tribunal emphasized the strict adherence to the law in reopening assessments after the prescribed period, ruling that the reassessment lacked merit.</description>
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      <description>The Tribunal upheld the decision of the Commissioner of Income Tax (Appeals) and dismissed the Revenue&#039;s appeal regarding the reopening of assessment for the assessment year 2007-08. It was found that the reassessment beyond the four-year period was not justified as it was based on a change of opinion by the Assessing Officer rather than any failure on the Assessee&#039;s part to disclose material facts. The Tribunal emphasized the strict adherence to the law in reopening assessments after the prescribed period, ruling that the reassessment lacked merit.</description>
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