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    <title>2018 (3) TMI 1997 - GUJARAT HIGH COURT</title>
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    <description>The court held that the notice for reopening the assessment under Section 148 of the Income Tax Act was invalid as it amounted to a change of opinion by the Assessing Officer. The court found that the issues regarding unexplained investments under Section 69 and the valuation of capital gains under Section 50C had already been scrutinized during the original assessment, and no additions were made based on these grounds. Therefore, the court allowed the petition and set aside the notice for reopening the assessment.</description>
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      <description>The court held that the notice for reopening the assessment under Section 148 of the Income Tax Act was invalid as it amounted to a change of opinion by the Assessing Officer. The court found that the issues regarding unexplained investments under Section 69 and the valuation of capital gains under Section 50C had already been scrutinized during the original assessment, and no additions were made based on these grounds. Therefore, the court allowed the petition and set aside the notice for reopening the assessment.</description>
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