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2022 (7) TMI 1472 - DELHI HIGH COURTReopening of assessment u/s 147 - ‘change of opinion’ - HELD THAT:- A perusal of the paper book reveals that the issue which is sought to be reopened in the proceeding u/s 148 had been discussed, deliberated and verified by the AO at the time of original assessment proceedings. It seems that the AO had applied its mind and then passed the assessment order in favour of the petitioner. While passing the impugned order u/s 148A(d) AO has wrongly concluded that the assessee had not disclosed the sale of the property and long term capital gain in the ITR filed or was accepted by the AO. Keeping in view the aforesaid, the impugned order and notice issued u/s 148A(d)/148 are set aside and the matter is remanded back to the AO for fresh consideration in accordance with law within four weeks.
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