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    <title>2026 (6) TMI 988 - GUJARAT HIGH COURT</title>
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    <description>Reopening under Section 148A(d) based on disallowance of a scientifically estimated warranty provision was invalid because the liability was a present obligation, reliably measurable from historical data and audited accounts, and deductible business expenditure under Section 37; the reassessment was quashed. Reopening on alleged non-taxation of forfeited security deposits taken against C-Forms was also invalid because the relevant facts had already been disclosed, the material was before the Assessing Officer, and the action amounted to a mere change of opinion; this ground too was quashed. The impugned notice and reassessment order for Assessment Year 2017-18 were held unsustainable, and the writ petition succeeded.</description>
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      <link>https://www.taxtmi.com/caselaws?id=793607</link>
      <description>Reopening under Section 148A(d) based on disallowance of a scientifically estimated warranty provision was invalid because the liability was a present obligation, reliably measurable from historical data and audited accounts, and deductible business expenditure under Section 37; the reassessment was quashed. Reopening on alleged non-taxation of forfeited security deposits taken against C-Forms was also invalid because the relevant facts had already been disclosed, the material was before the Assessing Officer, and the action amounted to a mere change of opinion; this ground too was quashed. The impugned notice and reassessment order for Assessment Year 2017-18 were held unsustainable, and the writ petition succeeded.</description>
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