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    <description>Reopening of assessment was challenged on the ground of failure to disclose material facts; the court found no fresh tangible material had come to the assessing officer&#039;s knowledge and therefore the reassessment notice under the reopening provision was invalid. The taxpayer&#039;s claims made during scrutiny, including claimed deductions raised and answered during enquiry, were considered in the original assessment and allowed; re-examination of the same material merely reflecting a different view could not justify reopening. The impugned notice and consequential orders were set aside.</description>
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      <description>Reopening of assessment was challenged on the ground of failure to disclose material facts; the court found no fresh tangible material had come to the assessing officer&#039;s knowledge and therefore the reassessment notice under the reopening provision was invalid. The taxpayer&#039;s claims made during scrutiny, including claimed deductions raised and answered during enquiry, were considered in the original assessment and allowed; re-examination of the same material merely reflecting a different view could not justify reopening. The impugned notice and consequential orders were set aside.</description>
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