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1980 (2) TMI 266 - HC - Income TaxExtract: .......e agree with the AAC that the change of opinion was on a highly debatable point. On either Court, the ITO had no jurisdiction to reopen the assessments. 8. In the result, we answer the question referred to us in negative in favour of the assessee and against the Department. The assessee will be entitled to costs which are assessed at ₹ 200/-.
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