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2018 (4) TMI 803 - HC - Income TaxReopening of assessment - reopening was made on the specific information from the Joint Commissioner of Income Tax, Special Range III, Mumbai, which was not available at the time of original assessment - Held that:- CIT (Appeals) considered the merits of the matters and regarding the details called for by the AO, after issuance of notice u/s 148 as rightly pointed out by the CIT (Appeals) and affirmed by the Tribunal, AO has attempted to make a roving enquiry in the course of reassessment proceedings and has attempted to collect evidence to support the initiation of proceedings under Section 148 of the Act. There is no material to show as to how the Joint Commissioner of Income Tax, Special Range III, Mumbai, came to the conclusion that the value of the assets should be determined as NIL. Thus, we find that the impugned reassessment proceedings was a clear case of change of opinion and therefore, the proceedings could not have been initiated under Section 147 of the Act. There is no error or infirmity in the orders passed by the Tribunal. - Decided in favour of assessee.
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