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    <title>2023 (2) TMI 716 - BOMBAY HIGH COURT</title>
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    <description>The court held that the notice issued under section 148 of the Income Tax Act was invalid as it lacked independent application of mind and tangible new material. Reopening the assessment beyond four years without evidence of non-disclosure was deemed unjustified. The court found that the petitioner had fully disclosed all relevant information during the original assessment, rendering the reopening invalid. Additionally, the transfer of jurisdiction without a hearing was considered improper. The court emphasized the need for independent evaluation in each case and set aside the notice and order, highlighting the importance of following due process.</description>
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    <pubDate>Wed, 15 Feb 2023 00:00:00 +0530</pubDate>
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      <title>2023 (2) TMI 716 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=434201</link>
      <description>The court held that the notice issued under section 148 of the Income Tax Act was invalid as it lacked independent application of mind and tangible new material. Reopening the assessment beyond four years without evidence of non-disclosure was deemed unjustified. The court found that the petitioner had fully disclosed all relevant information during the original assessment, rendering the reopening invalid. Additionally, the transfer of jurisdiction without a hearing was considered improper. The court emphasized the need for independent evaluation in each case and set aside the notice and order, highlighting the importance of following due process.</description>
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