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2017 (7) TMI 1159 - HC - Income TaxReopening of assessment - reasons to believe - Held that:- For the assessment year 2007-08 in case of the assessee, original scrutiny assessment was framed after which to reopen the assessment, the Assessing Officer issued a notice within four years from the end of the relevant assessment year. In the reasons recorded, he had indicated two grounds. One was with respect to treating certain income as business income instead of capital gain. Second was with respect to disallowance under section 14A of the Act. The Tribunal, in the impugned judgement, noticed that during the original assessment, both these questions were examined by the Assessing Officer for which, specific queries were raised. That being the position, we see no error in the view of the Tribunal that reassessment would be based on mere change of opinion. - Decided against revenue
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