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    <title>2026 (6) TMI 833 - GUJARAT HIGH COURT</title>
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    <description>Reassessment under section 147 was stated to be invalid where the alleged depreciation error did not affect tax liability under section 115JB and the original scrutiny assessment had already examined the depreciation claim. The text notes that the reassessment was sought only on the same material already on record, with the impact limited to business-income computation and the section 80-IA deduction, while tax remained governed by MAT on audited book profit. It further records that no escapement of income chargeable to tax was shown and the reopening amounted to a mere change of opinion. On that basis, the reopening conditions were not satisfied and the reassessment under section 148A(3) could not be sustained.</description>
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    <pubDate>Mon, 08 Jun 2026 00:00:00 +0530</pubDate>
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      <title>2026 (6) TMI 833 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=793452</link>
      <description>Reassessment under section 147 was stated to be invalid where the alleged depreciation error did not affect tax liability under section 115JB and the original scrutiny assessment had already examined the depreciation claim. The text notes that the reassessment was sought only on the same material already on record, with the impact limited to business-income computation and the section 80-IA deduction, while tax remained governed by MAT on audited book profit. It further records that no escapement of income chargeable to tax was shown and the reopening amounted to a mere change of opinion. On that basis, the reopening conditions were not satisfied and the reassessment under section 148A(3) could not be sustained.</description>
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      <pubDate>Mon, 08 Jun 2026 00:00:00 +0530</pubDate>
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