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    <title>2022 (2) TMI 706 - BOMBAY HIGH COURT</title>
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    <description>The High Court ruled in favor of the petitioner, holding that the Assessing Officer lacked authority to reopen assessment proceedings based on a change of opinion without any undisclosed material facts. The court emphasized that when all primary facts were disclosed during the original assessment, reassessment on a different interpretation was impermissible. As a result, the notice dated 31st March 2019 and the order dated 22nd November 2019 were quashed, and the petition was disposed of in favor of the petitioner.</description>
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      <title>2022 (2) TMI 706 - BOMBAY HIGH COURT</title>
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      <description>The High Court ruled in favor of the petitioner, holding that the Assessing Officer lacked authority to reopen assessment proceedings based on a change of opinion without any undisclosed material facts. The court emphasized that when all primary facts were disclosed during the original assessment, reassessment on a different interpretation was impermissible. As a result, the notice dated 31st March 2019 and the order dated 22nd November 2019 were quashed, and the petition was disposed of in favor of the petitioner.</description>
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