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1983 (7) TMI 46 - HC - Income TaxExtract: .......inion, it is well established that the change of opinion cannot form the basis for reopening the assessment under s. 147(b). In this view, we are inclined to agree with the view taken by the Tribunal. The question is, therefore, answered in the affirmative and against the Revenue. The Revenue will pay the costs to the assessee. Counsel fee Rs. 500.
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