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    <title>2022 (4) TMI 1080 - GUJARAT HIGH COURT</title>
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    <description>The Court quashed the notice issued under Section 148 of the Income Tax Act, 1961 for reopening the assessment for A.Y. 2014-15. The Court found that the reasons for reopening were known during the initial assessment, indicating a mere change of opinion without new material. It was determined that there was no failure in disclosure, and the objections raised against reopening were justified. As a result, the Court allowed the writ application, staying the implementation of the notice.</description>
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      <description>The Court quashed the notice issued under Section 148 of the Income Tax Act, 1961 for reopening the assessment for A.Y. 2014-15. The Court found that the reasons for reopening were known during the initial assessment, indicating a mere change of opinion without new material. It was determined that there was no failure in disclosure, and the objections raised against reopening were justified. As a result, the Court allowed the writ application, staying the implementation of the notice.</description>
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