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    <title>2021 (1) TMI 536 - ITAT DELHI</title>
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    <description>The Tribunal ruled in favor of the assessee, holding that the reassessment under section 147 was invalid. The AO&#039;s decision to reopen the assessment solely for the omitted disallowance of interest paid on loans, which had already been partially addressed in the original assessment, was deemed impermissible. As the assessee had disclosed all relevant facts during the initial assessment, the reassessment was considered unjustified and based on a mere change of opinion. Consequently, the Tribunal set aside the lower authorities&#039; orders, quashed the reassessment, and deleted all additions, ultimately allowing the assessee&#039;s appeal.</description>
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      <title>2021 (1) TMI 536 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=402944</link>
      <description>The Tribunal ruled in favor of the assessee, holding that the reassessment under section 147 was invalid. The AO&#039;s decision to reopen the assessment solely for the omitted disallowance of interest paid on loans, which had already been partially addressed in the original assessment, was deemed impermissible. As the assessee had disclosed all relevant facts during the initial assessment, the reassessment was considered unjustified and based on a mere change of opinion. Consequently, the Tribunal set aside the lower authorities&#039; orders, quashed the reassessment, and deleted all additions, ultimately allowing the assessee&#039;s appeal.</description>
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      <pubDate>Thu, 14 Jan 2021 00:00:00 +0530</pubDate>
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