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    <title>2021 (4) TMI 75 - GUJARAT HIGH COURT</title>
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    <description>The court held that the notice issued under Section 148 of the Income Tax Act to reopen the assessment was without authority of law. It was deemed that the reassessment was based on a mere change of opinion, lacking new tangible material. The court found that the conditions for reopening after four years were not met, as the assessee had disclosed all material facts during the original assessment. Therefore, the notice was quashed, and the writ application was allowed.</description>
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      <description>The court held that the notice issued under Section 148 of the Income Tax Act to reopen the assessment was without authority of law. It was deemed that the reassessment was based on a mere change of opinion, lacking new tangible material. The court found that the conditions for reopening after four years were not met, as the assessee had disclosed all material facts during the original assessment. Therefore, the notice was quashed, and the writ application was allowed.</description>
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