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    <title>2021 (4) TMI 1227 - MADRAS HIGH COURT</title>
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    <description>Reopening of assessment under Section 147 was treated as valid where fresh information on undervaluation of immovable property emerged after scrutiny assessment under Section 143(3). The sale deed value, stamp duty valuation and proceedings under Section 47A of the Indian Stamp Act were treated as new material showing a possible shortfall in long-term capital gains, satisfying the reason to believe requirement. The challenge based on change of opinion was rejected because the material had not been considered in the original assessment, and the reassessment was upheld.</description>
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