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2016 (7) TMI 1044 - HC - Income TaxReopening of assessment - Held that:- Having regard to the fact that the assessment under section 143(3) read with section 147 of the Act came to be framed by the very same officer who has recorded the reasons for reopening the assessment, it has been contended by the learned advocate for the petitioner that the concerned officer during the course of assessment proceedings under section 143(3) read with section 147 of the Act, was well aware of the order under section 263 of the Act and hence, this is a case of mere change of opinion on the part of the Assessing Officer and therefore, the reopening of assessment is bad in law. - Decided in favour of assessee.
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