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2016 (11) TMI 1563 - AT - Income TaxReopening of assessment - validity of reasons to believe - change of opinion - Held that:- If specific queries were raised during the course of original assessment proceedings to which specific replies were filed by the assessee supported by relevant documentary evidences, issuing notice u/s 148 to re-open the assessment on the very same issues considered at the time of the original assessment proceedings amount to change of opinion. As relying on CIT vs. Kelvinator of India Ltd, reported in [2010 (1) TMI 11 - SUPREME COURT OF INDIA] Notice issued u/s 148 of the Act was without jurisdiction and deserves to be quashed. - decided in favour of assessee.
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