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2013 (12) TMI 14 - HC - Income TaxReassessment u/s 147 - Held that:- Earlier the assessment was being made in the capaty of HUF - Later on the reassessment was started in the capacity of AOP - The assessee has disclosed all the material facts and on the basis, the assessment had been made - No relevant material was brought by the A.O. for changing the status - As per the CBDT Circular No.549 dated 31.10.1989 - When no new material was brought on record before changing the status, then it amounts to "change of opinion", which cannot be a ground for re-assessment - Following CIT Vs. Kalvinator of India [2002 (4) TMI 37 - DELHI High Court] - There must be some tangible new material before changing the status - The same is absent in the instant cases - Decided in favour of assessee.
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