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    <title>2020 (1) TMI 123 - ITAT JAIPUR</title>
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    <description>Profit from sale of rural agricultural land was not excluded from book profit under section 115JB on the facts of the case, with the ITAT following the earlier view already affirmed by the High Court and finding no change in facts. Reassessment under section 147 was held invalid because the original scrutiny assessment had already examined the same primary facts, no new tangible material had emerged, and the reopening was based only on a different legal view of disclosed material, amounting to a change of opinion. The MAT addition was sustained, but the reopening was quashed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=390510</link>
      <description>Profit from sale of rural agricultural land was not excluded from book profit under section 115JB on the facts of the case, with the ITAT following the earlier view already affirmed by the High Court and finding no change in facts. Reassessment under section 147 was held invalid because the original scrutiny assessment had already examined the same primary facts, no new tangible material had emerged, and the reopening was based only on a different legal view of disclosed material, amounting to a change of opinion. The MAT addition was sustained, but the reopening was quashed.</description>
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