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2009 (10) TMI 12 - HC - Income TaxIssue of notice u/s 147 – denial of exemption u/s 54 – held that - the matter went before the Commissioner of Income-tax (Appeals), who took the view that it was not really a case of escaped assessment, but was one of change of opinion by the assessing Authority - when the reassessment notices were issued and when admittedly there is no failure on the part of the assessee, who disclosed fully and truly all the material facts for assessment, it can only be construed as change of opinion and that it will not come under the category of escapement of assessment – revenue appeal dismissed.
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