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2009 (8) TMI 57 - DELHI HIGH COURT
Re-opening of an assessment – change of opinion - The Audit Report merely gives an opinion with regard to the non-availability of the deduction both under Section 80-IA and under Section 80-HHC and that the deduction under Section 80-IA was not deducted from the profits of the business while computing deduction under Section 80-HHC. Clearly, therefore, there was no new or fresh material before the Assessing Officer except the opinion of the Revenue Audit Party - . it is settled law that mere change of opinion cannot form the basis for issuing of a notice under Section 147/148 of the Act – proceedings initiated u/s 148 quashed