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    <title>2021 (11) TMI 419 - ITAT SURAT</title>
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    <description>The Tribunal allowed the appeals filed by the assessee for the relevant assessment years. The delay in filing appeals was condoned as unintentional, and the Tribunal admitted the appeals for hearing on merit. Regarding the validity of the reopening of assessment, the Tribunal held that it was unjustified as it was based on a change of opinion without new tangible material. The disallowance of excess depreciation on the JCB machine was overturned, with the Tribunal directing the deletion of the disallowance based on the machine&#039;s qualified higher depreciation rate.</description>
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      <title>2021 (11) TMI 419 - ITAT SURAT</title>
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      <description>The Tribunal allowed the appeals filed by the assessee for the relevant assessment years. The delay in filing appeals was condoned as unintentional, and the Tribunal admitted the appeals for hearing on merit. Regarding the validity of the reopening of assessment, the Tribunal held that it was unjustified as it was based on a change of opinion without new tangible material. The disallowance of excess depreciation on the JCB machine was overturned, with the Tribunal directing the deletion of the disallowance based on the machine&#039;s qualified higher depreciation rate.</description>
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