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    <title>2024 (3) TMI 730 - BOMBAY HIGH COURT</title>
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    <description>The Bombay HC ruled in favor of the assessee, holding that the AO lacked valid reasons to believe for reopening assessment. The court found no failure by the petitioner to disclose material facts fully and truly, as all details were provided during original assessment. The AO&#039;s reliance on audit objections without independent application of mind was insufficient justification. The petitioner had satisfactorily explained all audit queries through their chartered accountant, and the AO took no corrective action for 26 months, indicating acceptance of explanations. The reopening notice failed to identify any tangible material or undisclosed facts that would justify reassessment.</description>
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      <title>2024 (3) TMI 730 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=450949</link>
      <description>The Bombay HC ruled in favor of the assessee, holding that the AO lacked valid reasons to believe for reopening assessment. The court found no failure by the petitioner to disclose material facts fully and truly, as all details were provided during original assessment. The AO&#039;s reliance on audit objections without independent application of mind was insufficient justification. The petitioner had satisfactorily explained all audit queries through their chartered accountant, and the AO took no corrective action for 26 months, indicating acceptance of explanations. The reopening notice failed to identify any tangible material or undisclosed facts that would justify reassessment.</description>
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