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2017 (4) TMI 1344 - AT - Income TaxReopening of assessment - no fresh or tangible materials - Held that:- The initiation of re-assessment proceedings was based on a change of opinion and not on any fresh or tangible materials or on account of failure of assessee. Hon’ble Apex Court in the case of CIT vs. Kelvinator of India Ltd [2010 (1) TMI 11 - SUPREME COURT OF INDIA] has clearly held that no reopening could be made without tangible materials showing escapement of income, where original assessment was completed u/s.143(3) of the Act. Thus the impugned reassessment proceeding was rightly held by the ld.CIT(A) to be invalid - Decided against revenue
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