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    <title>2020 (6) TMI 301 - MADRAS HIGH COURT</title>
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    <description>The Court held that the reopening of assessments under Section 148 of the Income Tax Act for the Assessment Years 2010-2011 &amp;amp; 2011-2012 was without jurisdiction. It was found that the petitioner had disclosed the merger details in the returns, and there was no suppression of facts. The Court emphasized the principle against a change of opinion post-disclosure and directed the respondent to conclude the proceedings within three months. The petitioner was allowed to participate in proceedings, maintaining the adjustments made under Section 72A(1)(a) of the Act, while leaving open the possibility for reassessment on other grounds under Explanation 3 to Section 147.</description>
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      <title>2020 (6) TMI 301 - MADRAS HIGH COURT</title>
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      <description>The Court held that the reopening of assessments under Section 148 of the Income Tax Act for the Assessment Years 2010-2011 &amp;amp; 2011-2012 was without jurisdiction. It was found that the petitioner had disclosed the merger details in the returns, and there was no suppression of facts. The Court emphasized the principle against a change of opinion post-disclosure and directed the respondent to conclude the proceedings within three months. The petitioner was allowed to participate in proceedings, maintaining the adjustments made under Section 72A(1)(a) of the Act, while leaving open the possibility for reassessment on other grounds under Explanation 3 to Section 147.</description>
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