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    <title>2025 (4) TMI 2060 - ITAT CHENNAI</title>
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    <description>Reopening based solely on survey material already available to the Assessing Officer cannot be used to reappraise matters for which scrutiny could previously have been initiated. For Assessment Year 2012-13, reassessment initiated after four years without fresh tangible material constituted an impermissible review and was void. For Assessment Year 2013-14, reopening of a completed scrutiny assessment also required proof of income escapement and failure to make a full and true disclosure of material facts. As the reasons merely revisited examined material and showed neither requirement, the reassessment was invalid as a change of opinion.</description>
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      <description>Reopening based solely on survey material already available to the Assessing Officer cannot be used to reappraise matters for which scrutiny could previously have been initiated. For Assessment Year 2012-13, reassessment initiated after four years without fresh tangible material constituted an impermissible review and was void. For Assessment Year 2013-14, reopening of a completed scrutiny assessment also required proof of income escapement and failure to make a full and true disclosure of material facts. As the reasons merely revisited examined material and showed neither requirement, the reassessment was invalid as a change of opinion.</description>
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