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    <title>2022 (5) TMI 1575 - BOMBAY HIGH COURT</title>
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    <description>The court allowed the petition, quashing the notice under Section 148 of the Income Tax Act for Assessment Year 2014-2015 and subsequent proceedings. The court held that the reopening of assessment was a mere change of opinion as all relevant facts had been disclosed earlier. The respondent&#039;s argument regarding share premium valuation was dismissed as the valuation report was undisputed. Since non-disclosure of material facts was not established, the court did not address the applicability of Rule 11UA of the Income Tax Rules. The legal proceedings were concluded in line with the petitioner&#039;s prayer clause.</description>
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      <description>The court allowed the petition, quashing the notice under Section 148 of the Income Tax Act for Assessment Year 2014-2015 and subsequent proceedings. The court held that the reopening of assessment was a mere change of opinion as all relevant facts had been disclosed earlier. The respondent&#039;s argument regarding share premium valuation was dismissed as the valuation report was undisputed. Since non-disclosure of material facts was not established, the court did not address the applicability of Rule 11UA of the Income Tax Rules. The legal proceedings were concluded in line with the petitioner&#039;s prayer clause.</description>
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