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    <title>2021 (3) TMI 1330 - GUJARAT HIGH COURT</title>
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    <description>The court found the notice issued under Section 148 of the Income Tax Act invalid as the necessary details were already provided by the assessees. It determined that the reopening of the income tax assessment lacked a valid basis, as the assessees had disclosed the required information before the reasons for reopening were recorded. The court held that the reassessment was impermissible as it was based on a mere change of opinion by the Assessing Officer without any new material, violating established legal principles. Consequently, the court quashed the notices and allowed the writ applications, emphasizing the lack of jurisdiction in the reassessment for the relevant assessment year.</description>
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      <title>2021 (3) TMI 1330 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=300748</link>
      <description>The court found the notice issued under Section 148 of the Income Tax Act invalid as the necessary details were already provided by the assessees. It determined that the reopening of the income tax assessment lacked a valid basis, as the assessees had disclosed the required information before the reasons for reopening were recorded. The court held that the reassessment was impermissible as it was based on a mere change of opinion by the Assessing Officer without any new material, violating established legal principles. Consequently, the court quashed the notices and allowed the writ applications, emphasizing the lack of jurisdiction in the reassessment for the relevant assessment year.</description>
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