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    <title>2021 (4) TMI 383 - ITAT KOLKATA</title>
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    <description>The Tribunal held that the re-opening of assessment beyond four years under Section 147 of the Income Tax Act was invalid due to the absence of any failure to disclose material facts in the reasons for re-opening. The assessment was deemed legally unsustainable as it did not involve a change of opinion by the Assessing Officer and was based on the same material as the original assessment. Relying on legal precedents, the Tribunal quashed the assessment, emphasizing the necessity of adhering to statutory requirements for valid re-opening of assessments under Section 147.</description>
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      <description>The Tribunal held that the re-opening of assessment beyond four years under Section 147 of the Income Tax Act was invalid due to the absence of any failure to disclose material facts in the reasons for re-opening. The assessment was deemed legally unsustainable as it did not involve a change of opinion by the Assessing Officer and was based on the same material as the original assessment. Relying on legal precedents, the Tribunal quashed the assessment, emphasizing the necessity of adhering to statutory requirements for valid re-opening of assessments under Section 147.</description>
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