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    <title>2023 (10) TMI 137 - BOMBAY HIGH COURT</title>
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    <description>The court allowed the petition, quashing the notices and orders dated 17th March 2023 and 30th March 2023 under Section 148 of the Income Tax Act, 1961. It concluded that the reassessment was impermissibly based on a change of opinion, as the issue of non-deduction of TDS on payments was previously addressed and accepted during the original assessment. The court reiterated that a change of opinion does not justify reopening an assessment, thus setting aside the impugned actions. The petition was disposed of in favor of the petitioner.</description>
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    <pubDate>Tue, 26 Sep 2023 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=443914</link>
      <description>The court allowed the petition, quashing the notices and orders dated 17th March 2023 and 30th March 2023 under Section 148 of the Income Tax Act, 1961. It concluded that the reassessment was impermissibly based on a change of opinion, as the issue of non-deduction of TDS on payments was previously addressed and accepted during the original assessment. The court reiterated that a change of opinion does not justify reopening an assessment, thus setting aside the impugned actions. The petition was disposed of in favor of the petitioner.</description>
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      <pubDate>Tue, 26 Sep 2023 00:00:00 +0530</pubDate>
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