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    <title>2023 (9) TMI 626 - BOMBAY HIGH COURT</title>
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    <description>Reopening an assessment beyond four years was examined solely on whether there was failure to truly and fully disclose material facts; because the taxpayer filed returns and a government notification fixing market value was available during assessment and accepted by the assessing officer, reopening on those grounds was not justified. Separately, an amendment to the valuation rule treating stamp valuation at agreement date as full consideration was argued to apply retrospectively; the appellate authority accepted that approach and directed reassessment using the agreement date stamp valuation, leaving the impugned reopening notice without effect.</description>
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      <description>Reopening an assessment beyond four years was examined solely on whether there was failure to truly and fully disclose material facts; because the taxpayer filed returns and a government notification fixing market value was available during assessment and accepted by the assessing officer, reopening on those grounds was not justified. Separately, an amendment to the valuation rule treating stamp valuation at agreement date as full consideration was argued to apply retrospectively; the appellate authority accepted that approach and directed reassessment using the agreement date stamp valuation, leaving the impugned reopening notice without effect.</description>
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