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    <title>2023 (2) TMI 927 - BOMBAY HIGH COURT</title>
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    <description>The Court allowed the petition, ruling that the Notice dated 30th March 2021 and the order dated 21st February 2022 were unsustainable and set them aside. The reassessment proceedings were deemed bad due to a change of opinion, as the jurisdictional pre-conditions under section 147 of the Income Tax Act were not fulfilled. The Court emphasized that all relevant facts had been disclosed and considered during the assessment, and the Assessing Officer failed to establish any failure on the part of the assessee to disclose material facts.</description>
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      <description>The Court allowed the petition, ruling that the Notice dated 30th March 2021 and the order dated 21st February 2022 were unsustainable and set them aside. The reassessment proceedings were deemed bad due to a change of opinion, as the jurisdictional pre-conditions under section 147 of the Income Tax Act were not fulfilled. The Court emphasized that all relevant facts had been disclosed and considered during the assessment, and the Assessing Officer failed to establish any failure on the part of the assessee to disclose material facts.</description>
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