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2015 (6) TMI 176 - AT - Income TaxReopening of assessment - addition of claim of write–off of loans and advances due to non–recovery of amounts - Held that:- As relying on CIT v/s Jet Speed Audio Pvt. Ltd. [2015 (2) TMI 766 - BOMBAY HIGH COURT] wherein held Tribunal has rendered a finding of fact on the basis of material before it, in particular the fact that during original assessment proceedings a query was made with regard to the same issue which was responded to by the respondent - Assessee and on satisfaction of the same, the Assessing Officer had passed an assessment order. Therefore, reopening of assessment on an issue in respect of which a query was raised and responded to by the assessee would amount to a change of opinion. No mention of any tangible material in the reasons recorded for issuing reopening notice under Section 148 of the Act. we set aside the re–opening of the assessment and consequent re–assessment in present case - Decided in favour of assesse.
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