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    <title>2019 (3) TMI 1708 - PATNA HIGH COURT</title>
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    <description>Reassessment was held invalid because the reopening notice was issued after the statutory limitation period for departmental audit had expired. The court also found that the assessing authority had gone beyond the limited scope of remand by reopening issues not covered by it, without any fresh material emerging after the original assessment. As the reassessment was based on the same facts already considered, it amounted to a mere change of opinion, which cannot justify reassessment. The proceedings were therefore quashed as an abuse of statutory jurisdiction.</description>
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      <link>https://www.taxtmi.com/caselaws?id=285649</link>
      <description>Reassessment was held invalid because the reopening notice was issued after the statutory limitation period for departmental audit had expired. The court also found that the assessing authority had gone beyond the limited scope of remand by reopening issues not covered by it, without any fresh material emerging after the original assessment. As the reassessment was based on the same facts already considered, it amounted to a mere change of opinion, which cannot justify reassessment. The proceedings were therefore quashed as an abuse of statutory jurisdiction.</description>
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      <pubDate>Fri, 29 Mar 2019 00:00:00 +0530</pubDate>
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