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2003 (12) TMI 272 - ITAT CALCUTTA-CExtract: ....... taken by the apex Court in this regard. Thus, we find that the authorities below were not within their rights to initiate proceedings under s. 147 far less making an assessment on the basis of a mere change of opinion. In reversing their orders, we allow the grounds taken by the assessee. 10. In the result, the appeals of the assessee are allowed.
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