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    <title>2021 (12) TMI 880 - BOMBAY HIGH COURT</title>
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    <description>The court ruled in favor of the petitioner in a case challenging the notice under section 148 of the Income Tax Act for reopening the assessment for Assessment Year 2012-13. The court found that the reasons for reopening were not based on fresh tangible material but on existing information from the original assessment. As the petitioner had fully disclosed all material facts necessary for assessment during the original process, the court held that the Assessing Officer exceeded jurisdiction in reopening the assessment. The court quashed the notice and rejection of objections, citing legal precedent that reopening assessments based on a change of opinion is not justified when primary facts are fully disclosed.</description>
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      <title>2021 (12) TMI 880 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=416114</link>
      <description>The court ruled in favor of the petitioner in a case challenging the notice under section 148 of the Income Tax Act for reopening the assessment for Assessment Year 2012-13. The court found that the reasons for reopening were not based on fresh tangible material but on existing information from the original assessment. As the petitioner had fully disclosed all material facts necessary for assessment during the original process, the court held that the Assessing Officer exceeded jurisdiction in reopening the assessment. The court quashed the notice and rejection of objections, citing legal precedent that reopening assessments based on a change of opinion is not justified when primary facts are fully disclosed.</description>
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      <pubDate>Mon, 13 Dec 2021 00:00:00 +0530</pubDate>
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