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    <title>2022 (2) TMI 316 - ITAT SURAT</title>
    <link>https://www.taxtmi.com/caselaws?id=418065</link>
    <description>The Tribunal held that the reopening of the assessment under Section 147/148 of the Income Tax Act for AY 2007-08 was not justified as it was based on an order under Section 263 that had been quashed. The Tribunal ruled that there was no new material to warrant the reopening and that it amounted to a change of opinion, prohibited by law. Consequently, the assessment order dated 25.02.2015 was quashed. Additionally, the addition of Rs. 1,68,69,977/- on account of alleged unexplained expenditure under Section 69 was not sustained. The appeal of the assessee was allowed in full.</description>
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    <pubDate>Thu, 02 Dec 2021 00:00:00 +0530</pubDate>
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      <title>2022 (2) TMI 316 - ITAT SURAT</title>
      <link>https://www.taxtmi.com/caselaws?id=418065</link>
      <description>The Tribunal held that the reopening of the assessment under Section 147/148 of the Income Tax Act for AY 2007-08 was not justified as it was based on an order under Section 263 that had been quashed. The Tribunal ruled that there was no new material to warrant the reopening and that it amounted to a change of opinion, prohibited by law. Consequently, the assessment order dated 25.02.2015 was quashed. Additionally, the addition of Rs. 1,68,69,977/- on account of alleged unexplained expenditure under Section 69 was not sustained. The appeal of the assessee was allowed in full.</description>
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      <pubDate>Thu, 02 Dec 2021 00:00:00 +0530</pubDate>
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