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    <title>2021 (10) TMI 71 - BOMBAY HIGH COURT</title>
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    <description>The court held that the Assessing Officer did not have jurisdiction to issue a notice under Section 148 of the Income Tax Act, as the reasons for reopening the assessment were not valid. The court found that the petitioner had disclosed all necessary material facts during the original assessment, and the reopening was based on a change of opinion, which is impermissible. Consequently, the court set aside the order, quashed the notice, and deemed the reopening of the assessment invalid.</description>
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      <description>The court held that the Assessing Officer did not have jurisdiction to issue a notice under Section 148 of the Income Tax Act, as the reasons for reopening the assessment were not valid. The court found that the petitioner had disclosed all necessary material facts during the original assessment, and the reopening was based on a change of opinion, which is impermissible. Consequently, the court set aside the order, quashed the notice, and deemed the reopening of the assessment invalid.</description>
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