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    <title>2022 (8) TMI 600 - ITAT PATNA</title>
    <link>https://www.taxtmi.com/caselaws?id=426361</link>
    <description>The Tribunal ruled in favor of the assessee, quashing the reassessment proceedings and deleting the related additions. It found that the reassessment initiated under section 147/148 was beyond the permissible period and constituted a change of opinion without new information, rendering it impermissible. The Tribunal also held that the separate addition of income from other sources and hire charges was not justified, as these amounts were already considered in the initial assessment. Additionally, the disallowance of deductions under section 40(b) was deemed unwarranted. Consequently, all appeals of the assessee were allowed, and the additions were deleted.</description>
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    <pubDate>Fri, 12 Aug 2022 00:00:00 +0530</pubDate>
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      <title>2022 (8) TMI 600 - ITAT PATNA</title>
      <link>https://www.taxtmi.com/caselaws?id=426361</link>
      <description>The Tribunal ruled in favor of the assessee, quashing the reassessment proceedings and deleting the related additions. It found that the reassessment initiated under section 147/148 was beyond the permissible period and constituted a change of opinion without new information, rendering it impermissible. The Tribunal also held that the separate addition of income from other sources and hire charges was not justified, as these amounts were already considered in the initial assessment. Additionally, the disallowance of deductions under section 40(b) was deemed unwarranted. Consequently, all appeals of the assessee were allowed, and the additions were deleted.</description>
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      <pubDate>Fri, 12 Aug 2022 00:00:00 +0530</pubDate>
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