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2007 (8) TMI 325 - HC - Income TaxDeduction claimed u/s 80I allowed – but on investigation AO found that the milk plant reflected by the assessee in the balance-sheet was actually constructed by the Punjab Dairy and not by assessee - some facts had come to the notice of the AO subsequent to the framing of the assessment - prima facie belief of AO that the income of the assessee had escaped assessment was justified - assumption of jurisdiction u/s 147 by the AO is valid - Tribunal is correct in holding that the notice issued u/s 148 for reopening the assessment already completed does not amount to change of opinion as claimed by the assessee
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