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    <title>2024 (7) TMI 794 - GUJARAT HIGH COURT</title>
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    <description>Gujarat HC held that reopening of assessment beyond four years was invalid where assessee had fully disclosed all material facts including Form 10CCB, audited accounts, and statutory declarations with the return. The AO had examined the section 80IA(4) deduction claim during regular assessment by raising queries which were answered. The court found that reasons for reopening constituted mere change of opinion without live link to new material, as all relevant information was already available during original assessment proceedings. Notice for reopening beyond four-year period could not be sustained, ruling in favor of assessee.</description>
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      <title>2024 (7) TMI 794 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=755574</link>
      <description>Gujarat HC held that reopening of assessment beyond four years was invalid where assessee had fully disclosed all material facts including Form 10CCB, audited accounts, and statutory declarations with the return. The AO had examined the section 80IA(4) deduction claim during regular assessment by raising queries which were answered. The court found that reasons for reopening constituted mere change of opinion without live link to new material, as all relevant information was already available during original assessment proceedings. Notice for reopening beyond four-year period could not be sustained, ruling in favor of assessee.</description>
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      <pubDate>Fri, 05 Jul 2024 00:00:00 +0530</pubDate>
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