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    <title>2022 (2) TMI 596 - BOMBAY HIGH COURT</title>
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    <description>The court held that the notice issued under Section 148 of the Income Tax Act, 1961 was invalid due to being dispatched beyond the permissible period. It found that the reasons for reopening the assessment lacked tangible material and were based on a mere change of opinion, violating jurisdictional conditions. The court concluded that the Revenue failed to satisfy the requirements for reopening the assessment, leading to the petition being allowed. The notice and order rejecting objections were quashed and set aside, with no costs awarded.</description>
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      <link>https://www.taxtmi.com/caselaws?id=418345</link>
      <description>The court held that the notice issued under Section 148 of the Income Tax Act, 1961 was invalid due to being dispatched beyond the permissible period. It found that the reasons for reopening the assessment lacked tangible material and were based on a mere change of opinion, violating jurisdictional conditions. The court concluded that the Revenue failed to satisfy the requirements for reopening the assessment, leading to the petition being allowed. The notice and order rejecting objections were quashed and set aside, with no costs awarded.</description>
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