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    <title>2020 (4) TMI 287 - ITAT MUMBAI</title>
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    <description>Reassessment under section 147 was held invalid where the original section 143(3) assessment had already examined the same receipts, prior period income, sundry receipts and administrative expenses. The reopening was based on material already on record, and the reasons showed no new tangible material to support a belief that income had escaped assessment. On these facts, the action amounted to a mere change of opinion, which is impermissible. The reassessment was quashed, and the other grounds on merits were not examined.</description>
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