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    <title>2025 (4) TMI 1916 - ITAT MUMBAI</title>
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    <description>Reassessment initiated beyond four years from the end of the assessment year requires failure to disclose fully and truly all material facts where the original assessment was completed after scrutiny. Depreciation-related material, including the completion certificate and employee statements on whether the building, plant and machinery were put to use, had been disclosed, queried and considered in the original assessment. Reopening on the same material constituted a change of opinion rather than a failure of disclosure. The reassessment was therefore invalid, and the consequential orders were quashed.</description>
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      <description>Reassessment initiated beyond four years from the end of the assessment year requires failure to disclose fully and truly all material facts where the original assessment was completed after scrutiny. Depreciation-related material, including the completion certificate and employee statements on whether the building, plant and machinery were put to use, had been disclosed, queried and considered in the original assessment. Reopening on the same material constituted a change of opinion rather than a failure of disclosure. The reassessment was therefore invalid, and the consequential orders were quashed.</description>
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