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2010 (12) TMI 61 - DELHI HIGH COURT
Reopening of assessment - Assessing Officer has power to reopen, provided there is "tangible material" to come to the conclusion that there is escapement of income from assessment - Held that: - change of opinion cannot clothe the assessing officer with the jurisdiction to initiate the proceeding under Section 147 of the Act - initiation of proceeding is in the realm of change of opinion and the same is not sustainable - writ petition is allowed