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    <title>2025 (2) TMI 1960 - ITAT JAIPUR</title>
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    <description>Reopening of a completed scrutiny assessment was held impermissible where the disallowances had already been specifically examined in the original proceedings and no fresh tangible material was brought on record. The reassessment notice under sections 147 and 148 was treated as a mere change of opinion, and the existing coordinate-bench view on the same issue was followed in line with judicial discipline. On that basis, the reassessment foundation failed, the proceedings were quashed, and the assessee succeeded while the revenue&#039;s appeal failed.</description>
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      <description>Reopening of a completed scrutiny assessment was held impermissible where the disallowances had already been specifically examined in the original proceedings and no fresh tangible material was brought on record. The reassessment notice under sections 147 and 148 was treated as a mere change of opinion, and the existing coordinate-bench view on the same issue was followed in line with judicial discipline. On that basis, the reassessment foundation failed, the proceedings were quashed, and the assessee succeeded while the revenue&#039;s appeal failed.</description>
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