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2006 (10) TMI 138 - HC - Income TaxNotice for re-opening assessment – reason given to issue notice was that that during the course of assessment proceedings for the A.Y. 2002-03, it came to light that claim of the assessee for deduction u/s 80P(2)(a)(i) was erroneous as the assessee was not registered under the Banking Regulation Act, 1949 & was not a member of clearing house & was providing facilities to non-members – notice is not based merely on change of opinion but also on the subsequent judgment of the SC – notice is valid
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