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2014 (5) TMI 627 - HC - Income TaxValidity of reopening of assessment u/s 147 and 148 of the Act – Mere change of opinion – Held that:- The assessment could not have been reopened in the manner done by the AO - When the assessee had disclosed all the details, particulars and the income was assessed, then, mere change of opinion would not justify passing of the order dated 31st March, 2003, is the conclusion reached concurrently in this case - The assessment years under consideration, namely, 1993-1994 to 1997-1998, the assessee disclosed the income and on identical lines that was assessed - If that was assessed, there was no necessity of issuing a notice to reopen it and particularly when there is no failure on the part of the assessee to disclose fully and precisely all material facts necessary for making an assessment – no substantial question of law arises for consideration – Decided against Revenue.
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