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    <title>1990 (8) TMI 20 - BOMBAY High Court</title>
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    <description>Reopening of an income-tax assessment under section 147(b) is invalid where it is based only on a change of opinion on the same material already examined in the original assessment. The record showed that the deduction had been considered earlier and no fresh information was received after completion of the assessment. A later appellate order could not supply the required information for reopening, particularly because reassessment had already been initiated before that order and the deduction was in any event allowed. The conditions precedent for valid reassessment were therefore not met, and the reopening was without jurisdiction.</description>
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    <pubDate>Tue, 21 Aug 1990 00:00:00 +0530</pubDate>
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      <title>1990 (8) TMI 20 - BOMBAY High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=21684</link>
      <description>Reopening of an income-tax assessment under section 147(b) is invalid where it is based only on a change of opinion on the same material already examined in the original assessment. The record showed that the deduction had been considered earlier and no fresh information was received after completion of the assessment. A later appellate order could not supply the required information for reopening, particularly because reassessment had already been initiated before that order and the deduction was in any event allowed. The conditions precedent for valid reassessment were therefore not met, and the reopening was without jurisdiction.</description>
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      <pubDate>Tue, 21 Aug 1990 00:00:00 +0530</pubDate>
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