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    <title>2023 (2) TMI 152 - ITAT DELHI</title>
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    <description>The Tribunal held that the reopening of assessment under Section 147 was invalid as the Assessing Officer lacked tangible material and proceeded based on a relook at the original assessment proceedings. The Tribunal found that there was no failure on the part of the assessee to disclose all material facts necessary for assessment, rendering the reopening invalid. Consequently, the assessment order was quashed, and the Commissioner (Appeals) decision was set aside. The Tribunal also noted that the alleged violation of Section 40A(3) in the assessment proceedings became academic after invalidating the reopening, leading to the allowance of the appeal.</description>
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    <pubDate>Wed, 28 Dec 2022 00:00:00 +0530</pubDate>
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      <title>2023 (2) TMI 152 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=433637</link>
      <description>The Tribunal held that the reopening of assessment under Section 147 was invalid as the Assessing Officer lacked tangible material and proceeded based on a relook at the original assessment proceedings. The Tribunal found that there was no failure on the part of the assessee to disclose all material facts necessary for assessment, rendering the reopening invalid. Consequently, the assessment order was quashed, and the Commissioner (Appeals) decision was set aside. The Tribunal also noted that the alleged violation of Section 40A(3) in the assessment proceedings became academic after invalidating the reopening, leading to the allowance of the appeal.</description>
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      <pubDate>Wed, 28 Dec 2022 00:00:00 +0530</pubDate>
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