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    <title>2022 (2) TMI 882 - BOMBAY HIGH COURT</title>
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    <description>The court quashed the notice and order, ruling that the reopening of the assessment was invalid under Section 147 of the Income Tax Act, 1961. The court held that there was no failure by the assessee to disclose material facts, and the reopening was based on a change in interpretation, which is impermissible. The petition was disposed of in favor of the petitioner, with no costs awarded.</description>
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      <description>The court quashed the notice and order, ruling that the reopening of the assessment was invalid under Section 147 of the Income Tax Act, 1961. The court held that there was no failure by the assessee to disclose material facts, and the reopening was based on a change in interpretation, which is impermissible. The petition was disposed of in favor of the petitioner, with no costs awarded.</description>
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