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    <title>2023 (3) TMI 284 - ITAT AHMEDABAD</title>
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    <description>The appeal was allowed, and reassessment proceedings were quashed by the Tribunal on jurisdictional grounds. The Tribunal found that the reassessment initiated beyond four years was time-barred and invalid as it was based on a mere &quot;change of opinion&quot; without new material. The assessee&#039;s contention that all material facts were disclosed during the original assessment was upheld. Other issues, including disallowance of prior period expenses, penalty proceedings, and charging of interest, were not separately adjudicated due to the quashing of reassessment. The order was pronounced on 03-03-2023.</description>
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      <title>2023 (3) TMI 284 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=434898</link>
      <description>The appeal was allowed, and reassessment proceedings were quashed by the Tribunal on jurisdictional grounds. The Tribunal found that the reassessment initiated beyond four years was time-barred and invalid as it was based on a mere &quot;change of opinion&quot; without new material. The assessee&#039;s contention that all material facts were disclosed during the original assessment was upheld. Other issues, including disallowance of prior period expenses, penalty proceedings, and charging of interest, were not separately adjudicated due to the quashing of reassessment. The order was pronounced on 03-03-2023.</description>
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