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    <title>2023 (3) TMI 98 - ITAT DELHI</title>
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    <description>The Tribunal upheld the reopening of assessment after four years, rejecting objections related to the limitation period and material information disclosure. The jurisdiction of the assessing officer was deemed valid despite challenges raised by the appellant. The reassessment based on a change of opinion was confirmed, leading to the addition related to share transactions. Despite contentions of adequate disclosure, the addition concerning cash deposits was upheld. The Tribunal partially allowed the appeal on cash deposits and share transactions, considering the appellant&#039;s submissions. Concerns regarding the opportunity of hearing and the merit of the case were addressed, resulting in a partial allowance of the appeal.</description>
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      <title>2023 (3) TMI 98 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=434712</link>
      <description>The Tribunal upheld the reopening of assessment after four years, rejecting objections related to the limitation period and material information disclosure. The jurisdiction of the assessing officer was deemed valid despite challenges raised by the appellant. The reassessment based on a change of opinion was confirmed, leading to the addition related to share transactions. Despite contentions of adequate disclosure, the addition concerning cash deposits was upheld. The Tribunal partially allowed the appeal on cash deposits and share transactions, considering the appellant&#039;s submissions. Concerns regarding the opportunity of hearing and the merit of the case were addressed, resulting in a partial allowance of the appeal.</description>
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