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    <title>2022 (4) TMI 974 - BOMBAY HIGH COURT</title>
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    <description>The court ruled in favor of the petitioner, a charitable Trust, in a case concerning the reopening of assessment for the Assessment Year 2016-2017 under the Income Tax Act. The court held that the proposed reopening was impermissible as it was based on a change of opinion without any new material justifying the action. It emphasized the importance of considering all relevant material during assessment proceedings and rejected the allegations of accumulation of income under different sections, as the petitioner had provided necessary details and explanations during the initial assessment process. The court quashed the notice for reopening and subsequent order, deeming them solely based on a change of opinion.</description>
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      <description>The court ruled in favor of the petitioner, a charitable Trust, in a case concerning the reopening of assessment for the Assessment Year 2016-2017 under the Income Tax Act. The court held that the proposed reopening was impermissible as it was based on a change of opinion without any new material justifying the action. It emphasized the importance of considering all relevant material during assessment proceedings and rejected the allegations of accumulation of income under different sections, as the petitioner had provided necessary details and explanations during the initial assessment process. The court quashed the notice for reopening and subsequent order, deeming them solely based on a change of opinion.</description>
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