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    <title>1983 (12) TMI 99 - ITAT CHANDIGARH</title>
    <link>https://www.taxtmi.com/caselaws?id=61007</link>
    <description>Reassessment under section 147(a) was invalid because the original assessment had already examined the cash credits and the reopening relied only on a general third-party statement that did not specifically implicate the assessee. The record showed that the assessee had disclosed the primary facts, and there was no rational connection or live link between the material received and any failure to fully and truly disclose material facts. A vague statement, without specific nexus or further verification, cannot justify reopening, and the attempt amounted to a mere change of opinion on the same material. The reassessment proceedings were therefore quashed.</description>
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    <pubDate>Fri, 30 Dec 1983 00:00:00 +0530</pubDate>
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      <title>1983 (12) TMI 99 - ITAT CHANDIGARH</title>
      <link>https://www.taxtmi.com/caselaws?id=61007</link>
      <description>Reassessment under section 147(a) was invalid because the original assessment had already examined the cash credits and the reopening relied only on a general third-party statement that did not specifically implicate the assessee. The record showed that the assessee had disclosed the primary facts, and there was no rational connection or live link between the material received and any failure to fully and truly disclose material facts. A vague statement, without specific nexus or further verification, cannot justify reopening, and the attempt amounted to a mere change of opinion on the same material. The reassessment proceedings were therefore quashed.</description>
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      <pubDate>Fri, 30 Dec 1983 00:00:00 +0530</pubDate>
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