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    <title>2025 (1) TMI 283 - ITAT DELHI</title>
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    <description>Reassessment under section 147 could not be sustained where the original section 143(3) assessment was completed after full disclosure of primary facts, including accounts, audit report and deduction details, and the Assessing Officer had already applied his mind to those materials. With no new tangible material brought on record, reopening on the same facts amounted to a prohibited review of the earlier assessment and was vitiated by mere change of opinion. The reassessment was therefore quashed.</description>
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      <description>Reassessment under section 147 could not be sustained where the original section 143(3) assessment was completed after full disclosure of primary facts, including accounts, audit report and deduction details, and the Assessing Officer had already applied his mind to those materials. With no new tangible material brought on record, reopening on the same facts amounted to a prohibited review of the earlier assessment and was vitiated by mere change of opinion. The reassessment was therefore quashed.</description>
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