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    <title>2009 (4) TMI 131 - BOMBAY HIGH COURT</title>
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    <description>A reopening notice under sections 147 and 148 was upheld where the earlier assessment under section 143(3) had not meaningfully examined the valuation and character of income from transfer of the right to purchase a plot. The recorded material showed that the Assessing Officer formed a reason to believe that income had escaped assessment after applying mind, so the case was not treated as a mere change of opinion. At the notice stage, the existence of relevant material and recorded reasons was sufficient, and writ interference was declined.</description>
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      <link>https://www.taxtmi.com/caselaws?id=34620</link>
      <description>A reopening notice under sections 147 and 148 was upheld where the earlier assessment under section 143(3) had not meaningfully examined the valuation and character of income from transfer of the right to purchase a plot. The recorded material showed that the Assessing Officer formed a reason to believe that income had escaped assessment after applying mind, so the case was not treated as a mere change of opinion. At the notice stage, the existence of relevant material and recorded reasons was sufficient, and writ interference was declined.</description>
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