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    <title>2025 (3) TMI 1123 - BOMBAY HIGH COURT</title>
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    <description>The Bombay HC partially upheld the reopening of assessment u/s 147. The court held that responses to audit memos cannot be considered as disclosure during assessment proceedings since they occur post-assessment. Reopening was upheld for rental figure differences and non-deduction of TDS on staff salary due to inadequate disclosure during original assessment. However, reopening was not upheld for depreciation claim on printers as the assessee had disclosed claiming 60% depreciation, showing prima facie compliance with disclosure requirements. The court noted that difference in total receipts appeared adequately explained during assessment proceedings, making reassessment potentially vulnerable on this ground.</description>
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    <pubDate>Wed, 19 Mar 2025 00:00:00 +0530</pubDate>
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      <title>2025 (3) TMI 1123 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=767737</link>
      <description>The Bombay HC partially upheld the reopening of assessment u/s 147. The court held that responses to audit memos cannot be considered as disclosure during assessment proceedings since they occur post-assessment. Reopening was upheld for rental figure differences and non-deduction of TDS on staff salary due to inadequate disclosure during original assessment. However, reopening was not upheld for depreciation claim on printers as the assessee had disclosed claiming 60% depreciation, showing prima facie compliance with disclosure requirements. The court noted that difference in total receipts appeared adequately explained during assessment proceedings, making reassessment potentially vulnerable on this ground.</description>
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      <pubDate>Wed, 19 Mar 2025 00:00:00 +0530</pubDate>
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