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1981 (2) TMI 56 - HC - Income TaxExtract: .......ied, the Tribunal, in our opinion, was right in holding that the ITO had wrongly exercised his jurisdiction in reopening the assessment under s. 147(a) of the Act. For all these reasons, the reference is answered in the affirmative and in favour of the assessee. In the circumstances of the case, parties shall bear their own costs of this reference.
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