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    <title>2025 (7) TMI 683 - CALCUTTA HIGH COURT</title>
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    <description>The HC upheld the Tribunal&#039;s decision allowing the assessee&#039;s appeal and setting aside the reopening of assessment under section 147. The Court found that the AO had accepted the assessee&#039;s audited books of accounts, supporting documents including purchase bills, excise declarations, VAT documents, and complete stock details during original assessment proceedings. Since the books were not rejected and transactions were substantiated with proper documentation including fifty supporting documents, the reopening was held invalid as it constituted a mere change of opinion rather than being based on fresh tangible evidence. The Tribunal was justified in concluding the reopening was bad in law.</description>
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    <pubDate>Tue, 08 Jul 2025 00:00:00 +0530</pubDate>
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      <title>2025 (7) TMI 683 - CALCUTTA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=774615</link>
      <description>The HC upheld the Tribunal&#039;s decision allowing the assessee&#039;s appeal and setting aside the reopening of assessment under section 147. The Court found that the AO had accepted the assessee&#039;s audited books of accounts, supporting documents including purchase bills, excise declarations, VAT documents, and complete stock details during original assessment proceedings. Since the books were not rejected and transactions were substantiated with proper documentation including fifty supporting documents, the reopening was held invalid as it constituted a mere change of opinion rather than being based on fresh tangible evidence. The Tribunal was justified in concluding the reopening was bad in law.</description>
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