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    <title>2021 (11) TMI 776 - BOMBAY HIGH COURT</title>
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    <description>The court set aside the notices and orders seeking to reopen assessments under Section 148 of the Income-tax Act for the Assessment Year 2012-2013. It held that the Assessing Officer could not reopen assessments based on a mere change of opinion without new material, especially when all relevant facts were disclosed during the original assessment. The court emphasized that the Assessing Officer lacked the authority to review concluded assessments without tangible evidence of income escapement. Therefore, the reopening of assessments solely on the grounds of advertisement and marketing expenses, previously considered during the initial assessment, was deemed impermissible.</description>
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    <pubDate>Mon, 15 Nov 2021 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=414995</link>
      <description>The court set aside the notices and orders seeking to reopen assessments under Section 148 of the Income-tax Act for the Assessment Year 2012-2013. It held that the Assessing Officer could not reopen assessments based on a mere change of opinion without new material, especially when all relevant facts were disclosed during the original assessment. The court emphasized that the Assessing Officer lacked the authority to review concluded assessments without tangible evidence of income escapement. Therefore, the reopening of assessments solely on the grounds of advertisement and marketing expenses, previously considered during the initial assessment, was deemed impermissible.</description>
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      <pubDate>Mon, 15 Nov 2021 00:00:00 +0530</pubDate>
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