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    <title>2022 (7) TMI 1454 - GUJARAT HIGH COURT</title>
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    <description>The court held that the notice issued under Section 148 of the Income Tax Act, 1961, for reopening the assessment for the Assessment Year 2011-2012 was illegal and quashed it. The court found that the reopening of the assessment was based on a mere change of opinion by the Assessing Officer, which was not permissible. Consequently, the order disposing of objections against the notice was also quashed. The petition was allowed, and no costs were awarded.</description>
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      <description>The court held that the notice issued under Section 148 of the Income Tax Act, 1961, for reopening the assessment for the Assessment Year 2011-2012 was illegal and quashed it. The court found that the reopening of the assessment was based on a mere change of opinion by the Assessing Officer, which was not permissible. Consequently, the order disposing of objections against the notice was also quashed. The petition was allowed, and no costs were awarded.</description>
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