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    <title>2022 (11) TMI 846 - ITAT RAJKOT</title>
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    <description>The Tribunal ruled in favor of the assessee, holding that the reassessment under section 147 of the Income Tax Act was not valid as it was solely based on a change of opinion without new material. The Tribunal found that the original documents were the basis for the reassessment and concluded that the proceedings were unsustainable. Consequently, the appeal was partly allowed on technical grounds, leading to the quashing of the proceedings initiated under section 147. The Tribunal did not address the merits of the appeal, deeming them moot.</description>
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      <title>2022 (11) TMI 846 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=430422</link>
      <description>The Tribunal ruled in favor of the assessee, holding that the reassessment under section 147 of the Income Tax Act was not valid as it was solely based on a change of opinion without new material. The Tribunal found that the original documents were the basis for the reassessment and concluded that the proceedings were unsustainable. Consequently, the appeal was partly allowed on technical grounds, leading to the quashing of the proceedings initiated under section 147. The Tribunal did not address the merits of the appeal, deeming them moot.</description>
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      <pubDate>Wed, 16 Nov 2022 00:00:00 +0530</pubDate>
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