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    <title>2022 (3) TMI 1474 - BOMBAY HIGH COURT</title>
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    <description>The High Court quashed the notice issued under Section 148 of the Income Tax Act, 1961 for Assessment Year 2013-2014 and the subsequent order on objections. The Court found that the reasons for reopening the assessment were based on a change of opinion rather than a failure to disclose material facts. As the Assessing Officer had added back only 1% of the total turnover/sales to the total income instead of the suggested 5%, indicating a clear change of opinion without justification, the Court concluded that the notice and order should be set aside. The petition was allowed, and the documents were quashed without costs.</description>
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    <pubDate>Mon, 07 Mar 2022 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=305975</link>
      <description>The High Court quashed the notice issued under Section 148 of the Income Tax Act, 1961 for Assessment Year 2013-2014 and the subsequent order on objections. The Court found that the reasons for reopening the assessment were based on a change of opinion rather than a failure to disclose material facts. As the Assessing Officer had added back only 1% of the total turnover/sales to the total income instead of the suggested 5%, indicating a clear change of opinion without justification, the Court concluded that the notice and order should be set aside. The petition was allowed, and the documents were quashed without costs.</description>
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