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    <title>2023 (2) TMI 351 - ITAT PUNE</title>
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    <description>The Tribunal found that the initiation of reassessment proceedings by the Assessing Officer (AO) was not justified as the assessee had fully disclosed all material facts during the original assessment. The discrepancies pointed out by the AO were considered a change of opinion rather than a failure to disclose relevant information. The Tribunal quashed the reassessment, citing a lack of alignment with relevant case law. Consequently, the appeal of the assessee was allowed, and that of the Revenue was dismissed as academic, emphasizing the importance of full and true disclosure of material facts by the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=433836</link>
      <description>The Tribunal found that the initiation of reassessment proceedings by the Assessing Officer (AO) was not justified as the assessee had fully disclosed all material facts during the original assessment. The discrepancies pointed out by the AO were considered a change of opinion rather than a failure to disclose relevant information. The Tribunal quashed the reassessment, citing a lack of alignment with relevant case law. Consequently, the appeal of the assessee was allowed, and that of the Revenue was dismissed as academic, emphasizing the importance of full and true disclosure of material facts by the assessee.</description>
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