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2012 (6) TMI 365 - HC - Wealth-taxRe- assessment - the Karta’s Minor daughter, the sole beneficiary under the Trust, her assessable wealth was not included in the assessment of HUF – Initiation of rectification proceedings immediately after first assessment - Held that:- The grounds on which reassessment proceedings was taken up were the same grounds for initiation of rectification proceedings under Section 35 also - mere change of opinion itself will not confer jurisdiction to reopen the assessment - it is evident that the AO initiated rectification proceedings only on the score that there is a mistake apparent on the face of the record and hence the assessment was to be revised, therefore it is obvious that the AO had all the materials before him when he invoked the jurisdiction for rectification of mistake, thus it stands to reason that the issuance of notice for re assessment that assessee had not disclosed the material facts fully and truly is totally without any jurisdiction - in favour of assessee.
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