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    <title>2022 (1) TMI 692 - BOMBAY HIGH COURT</title>
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    <description>The court quashed the notice for reopening assessment for A.Y. 2013-14, emphasizing that reassessment based on a change of opinion is unwarranted when primary facts are fully disclosed. The Assessing Officer&#039;s contentions regarding the valuation of shares and claimed expenses were deemed as a mere change of opinion, as these matters were adequately explained during assessment proceedings. The court highlighted the lack of disclosure by the Assessing Officer and ruled in favor of the petitioner, disposing of the petition with no order as to costs.</description>
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      <link>https://www.taxtmi.com/caselaws?id=417227</link>
      <description>The court quashed the notice for reopening assessment for A.Y. 2013-14, emphasizing that reassessment based on a change of opinion is unwarranted when primary facts are fully disclosed. The Assessing Officer&#039;s contentions regarding the valuation of shares and claimed expenses were deemed as a mere change of opinion, as these matters were adequately explained during assessment proceedings. The court highlighted the lack of disclosure by the Assessing Officer and ruled in favor of the petitioner, disposing of the petition with no order as to costs.</description>
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