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    <title>2019 (8) TMI 1070 - DELHI HIGH COURT</title>
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    <description>The Court upheld the ITAT&#039;s decision to quash the reassessment proceedings under Section 147 of the Income Tax Act, ruling that the reassessment was based on a change of opinion rather than new information or an independent belief by the Assessing Officer. The Court found that reopening the assessment solely on audit objections without an independent belief by the AO was impermissible, citing precedents. The appeal by the Revenue was dismissed as it did not meet the legal requirements of Section 147, and no substantial question of law was identified.</description>
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    <pubDate>Wed, 21 Aug 2019 00:00:00 +0530</pubDate>
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      <title>2019 (8) TMI 1070 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=384881</link>
      <description>The Court upheld the ITAT&#039;s decision to quash the reassessment proceedings under Section 147 of the Income Tax Act, ruling that the reassessment was based on a change of opinion rather than new information or an independent belief by the Assessing Officer. The Court found that reopening the assessment solely on audit objections without an independent belief by the AO was impermissible, citing precedents. The appeal by the Revenue was dismissed as it did not meet the legal requirements of Section 147, and no substantial question of law was identified.</description>
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      <pubDate>Wed, 21 Aug 2019 00:00:00 +0530</pubDate>
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