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    <title>2020 (2) TMI 1455 - ITAT MUMBAI</title>
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    <description>The Tribunal held that the reopening of assessment under section 147 of the Income Tax Act lacked jurisdiction as the reasons recorded did not establish reasonable belief of income escapement. The additions of income through client code modification and disallowance of loss and interest expenses were also deemed without jurisdiction based on the Bombay High Court&#039;s precedent. Consequently, the appellate proceedings were considered void, and the appeal for the assessment year 2010-2011 was allowed in favor of the assessee.</description>
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      <description>The Tribunal held that the reopening of assessment under section 147 of the Income Tax Act lacked jurisdiction as the reasons recorded did not establish reasonable belief of income escapement. The additions of income through client code modification and disallowance of loss and interest expenses were also deemed without jurisdiction based on the Bombay High Court&#039;s precedent. Consequently, the appellate proceedings were considered void, and the appeal for the assessment year 2010-2011 was allowed in favor of the assessee.</description>
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