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    <title>2025 (8) TMI 384 - GUJARAT HIGH COURT</title>
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    <description>Reopening under Section 148 based on alleged unpaid expenses under Section 43B was held unsustainable where the return, audit reports and supporting material were already on record. The Court found that the assessee had undergone scrutiny assessment, the impugned liabilities were shown as paid, reversed, transferred to creditors or adjusted through input tax credit, and the Assessing Officer did not meaningfully deal with the reply or existing material. Reopening founded mainly on Insight Portal information, without proper application of mind, was treated as an impermissible change of opinion. The notice under Section 148 and the order under Section 148A(d) were quashed.</description>
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      <title>2025 (8) TMI 384 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=776197</link>
      <description>Reopening under Section 148 based on alleged unpaid expenses under Section 43B was held unsustainable where the return, audit reports and supporting material were already on record. The Court found that the assessee had undergone scrutiny assessment, the impugned liabilities were shown as paid, reversed, transferred to creditors or adjusted through input tax credit, and the Assessing Officer did not meaningfully deal with the reply or existing material. Reopening founded mainly on Insight Portal information, without proper application of mind, was treated as an impermissible change of opinion. The notice under Section 148 and the order under Section 148A(d) were quashed.</description>
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