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    <title>2026 (7) TMI 746 - GUJARAT HIGH COURT</title>
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    <description>Reassessment beyond four years from the end of the assessment year is described as invalid where the original scrutiny had already examined the same issues and no fresh tangible material emerged later. The text states that matters relating to tax deduction at source and a write-off claim had been specifically called for, disclosed and considered in the original assessment, so reopening on those grounds amounted to a change of opinion. Its stated legal effect is that a notice under Section 148 and the order rejecting objections cannot be sustained in such circumstances and are liable to be quashed.</description>
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      <description>Reassessment beyond four years from the end of the assessment year is described as invalid where the original scrutiny had already examined the same issues and no fresh tangible material emerged later. The text states that matters relating to tax deduction at source and a write-off claim had been specifically called for, disclosed and considered in the original assessment, so reopening on those grounds amounted to a change of opinion. Its stated legal effect is that a notice under Section 148 and the order rejecting objections cannot be sustained in such circumstances and are liable to be quashed.</description>
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