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    <title>2025 (6) TMI 494 - GUJARAT HIGH COURT</title>
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    <description>The Gujarat HC held that reopening of assessment under section 147 was invalid where the assessee had fully disclosed all material facts regarding immovable property investments during regular assessment proceedings. The court found that purchase deeds were already filed with the AO during the original assessment. Since complete disclosure was made, the AO lacked jurisdiction to reopen assessment after four years based merely on change of opinion without tangible material showing escaped income. The reassessment notice was quashed in favor of the assessee.</description>
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      <title>2025 (6) TMI 494 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=772381</link>
      <description>The Gujarat HC held that reopening of assessment under section 147 was invalid where the assessee had fully disclosed all material facts regarding immovable property investments during regular assessment proceedings. The court found that purchase deeds were already filed with the AO during the original assessment. Since complete disclosure was made, the AO lacked jurisdiction to reopen assessment after four years based merely on change of opinion without tangible material showing escaped income. The reassessment notice was quashed in favor of the assessee.</description>
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      <pubDate>Tue, 06 May 2025 00:00:00 +0530</pubDate>
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