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    <title>2025 (2) TMI 1148 - BOMBAY HIGH COURT</title>
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    <description>The Bombay HC dismissed a writ petition challenging reopening of assessment under Section 147 based on audit objection. The petitioner failed to provide complete attachments and evidence to support claims that required details were already filed during regular assessment proceedings. The Court held it cannot examine factual issues regarding what documentation was submitted without proper evidence being placed on record. Since petitioner did not provide entire material to demonstrate change of opinion, the Court declined to exercise extraordinary jurisdiction and dismissed the petition, granting liberty to challenge reassessment before Appellate Authority when reassessment order is issued pursuant to Section 148 notice.</description>
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    <pubDate>Wed, 26 Feb 2025 00:00:00 +0530</pubDate>
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      <title>2025 (2) TMI 1148 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=766601</link>
      <description>The Bombay HC dismissed a writ petition challenging reopening of assessment under Section 147 based on audit objection. The petitioner failed to provide complete attachments and evidence to support claims that required details were already filed during regular assessment proceedings. The Court held it cannot examine factual issues regarding what documentation was submitted without proper evidence being placed on record. Since petitioner did not provide entire material to demonstrate change of opinion, the Court declined to exercise extraordinary jurisdiction and dismissed the petition, granting liberty to challenge reassessment before Appellate Authority when reassessment order is issued pursuant to Section 148 notice.</description>
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      <pubDate>Wed, 26 Feb 2025 00:00:00 +0530</pubDate>
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