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    <title>2023 (8) TMI 1025 - BOMBAY HIGH COURT</title>
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    <description>The court quashed the notice dated 27th March 2021 issued under Section 148 of the Income Tax Act, 1961, and subsequent orders, deeming them unsustainable as they were based on a change of opinion rather than new tangible material. The court held that reopening the assessment was invalid since the Assessing Officer had already scrutinized and allowed the depreciation claim on goodwill during the original assessment. The reassessment proceedings, influenced by audit objections without independent determination by the A.O., were set aside, and the petition was allowed.</description>
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      <description>The court quashed the notice dated 27th March 2021 issued under Section 148 of the Income Tax Act, 1961, and subsequent orders, deeming them unsustainable as they were based on a change of opinion rather than new tangible material. The court held that reopening the assessment was invalid since the Assessing Officer had already scrutinized and allowed the depreciation claim on goodwill during the original assessment. The reassessment proceedings, influenced by audit objections without independent determination by the A.O., were set aside, and the petition was allowed.</description>
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