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2016 (1) TMI 1485 - Income Tax
Validity of re-assessment u/s 147 - eligibility of reasons to believe - HELD THAT:- As there was no new material that had come to the possession of the Assessing Officer and since the assessment originally completed under section 143(3) was reopened by him on the basis of same material, which was available at the time of completion of original assessment under section 143(3), we are of the view that the reopening of assessment made by the Assessing Officer merely on the basis of change of opinion was bad in law.
Thus we are of the view that the reopening of assessment by the Assessing Officer in the present case itself was bad in law and the assessment computed by him under section 143(3) read with section 147 in pursuance thereof is invalid, which is liable to be cancelled - Decided in favour of assessee.