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    <title>2026 (2) TMI 1194 - BOMBAY HIGH COURT</title>
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    <description>Reopening under Section 148 was quashed because the asserted reasons relied on either an already deleted clerical-error addition or on cash deposits that had been specifically examined and accepted in the original scrutiny assessment; the court treated the reassessment attempt as a prohibited change of opinion where material facts were fully disclosed and considered, and therefore the notice dated 12.01.2021 and the order disposing objections dated 02.12.2021 were set aside in favour of the assessee.</description>
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      <description>Reopening under Section 148 was quashed because the asserted reasons relied on either an already deleted clerical-error addition or on cash deposits that had been specifically examined and accepted in the original scrutiny assessment; the court treated the reassessment attempt as a prohibited change of opinion where material facts were fully disclosed and considered, and therefore the notice dated 12.01.2021 and the order disposing objections dated 02.12.2021 were set aside in favour of the assessee.</description>
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