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2004 (9) TMI 667 - AT - Income TaxExtract: .......es was merely on the basis of change of opinion. Considering the above facts, we hold that the initiation of proceedings under section 147 of the Act as well as the additions made in the re-assessment order are invalid. The re-assessment orders are, therefore, cancelled. 13. In the result, all the three appeals directed by the assessee are allowed.
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