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    <title>1982 (5) TMI 47 - ITAT AHMEDABAD-C</title>
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    <description>The Tribunal upheld the Income Tax Officer&#039;s decision to reopen assessments under section 147(b) of the Income-tax Act, 1961, based on new information indicating income had escaped assessment. It was determined that the reopening was not a mere change of opinion but a valid action. The Tribunal also clarified that the audit note was not the sole basis for the reopening. As the Appellate Assistant Commissioner did not address the merits, the Tribunal directed a remand for a decision on the merits, concluding that it lacked jurisdiction to decide on them. All appeals were allowed for statistical purposes.</description>
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    <pubDate>Sat, 01 May 1982 00:00:00 +0530</pubDate>
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      <title>1982 (5) TMI 47 - ITAT AHMEDABAD-C</title>
      <link>https://www.taxtmi.com/caselaws?id=56194</link>
      <description>The Tribunal upheld the Income Tax Officer&#039;s decision to reopen assessments under section 147(b) of the Income-tax Act, 1961, based on new information indicating income had escaped assessment. It was determined that the reopening was not a mere change of opinion but a valid action. The Tribunal also clarified that the audit note was not the sole basis for the reopening. As the Appellate Assistant Commissioner did not address the merits, the Tribunal directed a remand for a decision on the merits, concluding that it lacked jurisdiction to decide on them. All appeals were allowed for statistical purposes.</description>
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      <pubDate>Sat, 01 May 1982 00:00:00 +0530</pubDate>
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