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    <title>2026 (2) TMI 372 - BOMBAY HIGH COURT</title>
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    <description>Reopening of assessment under Section 147 was challenged on limitation grounds and on validity of the notice issued after the Taxation and Other Laws (Relaxation and Amendment) Act, 2020 period. The court noted departmental concession in a binding Supreme Court precedent and held that delay by the taxpayer did not validate a notice otherwise legally invalid; consequently the impugned notice, the assessment order and all consequential and recovery notices for the assessment year were quashed and set aside. The taxpayer was directed to withdraw the pending appellate proceeding within two weeks of the order upload.</description>
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      <description>Reopening of assessment under Section 147 was challenged on limitation grounds and on validity of the notice issued after the Taxation and Other Laws (Relaxation and Amendment) Act, 2020 period. The court noted departmental concession in a binding Supreme Court precedent and held that delay by the taxpayer did not validate a notice otherwise legally invalid; consequently the impugned notice, the assessment order and all consequential and recovery notices for the assessment year were quashed and set aside. The taxpayer was directed to withdraw the pending appellate proceeding within two weeks of the order upload.</description>
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