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2009 (8) TMI 842 - ITAT MUMBAIExtract: ....... set of facts, without there being any additional information, can only be considered as change of opinion. As there is no case for Revenue for reopening on facts and law, it is to be held that reopening is bad in law on the facts of this case. Accordingly ground Nos. 3, 4 and 5 of the assessee are allowed. 10. In the result, appeal partly allowed.
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