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    <title>2024 (9) TMI 1572 - DELHI HIGH COURT</title>
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    <description>Reopening an assessment cannot be justified where the same facts and reasons were previously considered and rejected, because reassessment powers are confined to income that escaped the assessing officer&#039;s knowledge rather than a mere change of opinion; consequence: notices issued to reopen the assessment and related proceedings were quashed. The authority&#039;s prior decision to drop revision proceedings after considering the assessee&#039;s reply demonstrated that the grounds for reassessment were identical to matters already on record, so subsequent approval by a senior official could not validate the reopening which amounted to a review and was set aside.</description>
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      <description>Reopening an assessment cannot be justified where the same facts and reasons were previously considered and rejected, because reassessment powers are confined to income that escaped the assessing officer&#039;s knowledge rather than a mere change of opinion; consequence: notices issued to reopen the assessment and related proceedings were quashed. The authority&#039;s prior decision to drop revision proceedings after considering the assessee&#039;s reply demonstrated that the grounds for reassessment were identical to matters already on record, so subsequent approval by a senior official could not validate the reopening which amounted to a review and was set aside.</description>
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