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    <title>High Court Invalidates Reopening by AO: No New Tangible Material or &quot;Reasons to Believe&quot;; Section 148 Notice Quashed.</title>
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    <description>The High Court held that the reopening proceedings were invalid as the Assessing Officer (AO) lacked &quot;reasons to believe&quot; supported by fresh tangible material. The AO&#039;s basis for reopening did not show any failure by the assessee to fully disclose material facts. The assessment order u/s 143(3) only addressed excess depreciation claimed on a specific issue, indicating that the AO had already considered and made adjustments on this matter. Consequently, the notice issued u/s 148 was deemed untenable and was quashed in favor of the assessee.</description>
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    <pubDate>Tue, 13 Aug 2024 07:08:12 +0530</pubDate>
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      <title>High Court Invalidates Reopening by AO: No New Tangible Material or &quot;Reasons to Believe&quot;; Section 148 Notice Quashed.</title>
      <link>https://www.taxtmi.com/highlights?id=80396</link>
      <description>The High Court held that the reopening proceedings were invalid as the Assessing Officer (AO) lacked &quot;reasons to believe&quot; supported by fresh tangible material. The AO&#039;s basis for reopening did not show any failure by the assessee to fully disclose material facts. The assessment order u/s 143(3) only addressed excess depreciation claimed on a specific issue, indicating that the AO had already considered and made adjustments on this matter. Consequently, the notice issued u/s 148 was deemed untenable and was quashed in favor of the assessee.</description>
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      <pubDate>Tue, 13 Aug 2024 07:08:12 +0530</pubDate>
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