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    <title>2024 (3) TMI 1158 - BOMBAY HIGH COURT</title>
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    <description>The Bombay HC ruled in favor of the assessee, quashing reassessment proceedings under section 147. The court held that the AO&#039;s reopening was based on a mere change of opinion rather than valid reasons to believe income had escaped assessment. Since queries regarding the petitioner&#039;s equity share transactions were previously raised and replied to during original assessment proceedings, the AO had already considered these matters. The court found no failure by the assessee to disclose material facts and noted absence of a live link between available information and the AO&#039;s belief of income escapement, making jurisdictional conditions unmet.</description>
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    <pubDate>Mon, 18 Mar 2024 00:00:00 +0530</pubDate>
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      <title>2024 (3) TMI 1158 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=750661</link>
      <description>The Bombay HC ruled in favor of the assessee, quashing reassessment proceedings under section 147. The court held that the AO&#039;s reopening was based on a mere change of opinion rather than valid reasons to believe income had escaped assessment. Since queries regarding the petitioner&#039;s equity share transactions were previously raised and replied to during original assessment proceedings, the AO had already considered these matters. The court found no failure by the assessee to disclose material facts and noted absence of a live link between available information and the AO&#039;s belief of income escapement, making jurisdictional conditions unmet.</description>
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      <pubDate>Mon, 18 Mar 2024 00:00:00 +0530</pubDate>
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