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    <title>2023 (10) TMI 626 - BOMBAY HIGH COURT</title>
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    <description>The HC quashed the notice dated 30th March 2013 and the order dated 6th February 2014, ruling that the reopening of the assessment for A.Y. 2008-2009 was unjustified. The court determined that the reopening was based on a change of opinion, which is impermissible under Section 147 of the Income Tax Act. It was also found that Section 50C was not applicable to the transaction of gifting a flat, as previously accepted during the original assessment. The court noted that audit objections were not mentioned as the basis for reopening, and thus, could not serve as tangible material.</description>
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      <description>The HC quashed the notice dated 30th March 2013 and the order dated 6th February 2014, ruling that the reopening of the assessment for A.Y. 2008-2009 was unjustified. The court determined that the reopening was based on a change of opinion, which is impermissible under Section 147 of the Income Tax Act. It was also found that Section 50C was not applicable to the transaction of gifting a flat, as previously accepted during the original assessment. The court noted that audit objections were not mentioned as the basis for reopening, and thus, could not serve as tangible material.</description>
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