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2019 (8) TMI 998 - HC - Income TaxReopening of assessment u/s 147 - change of opinion - addition in respect of the transaction as to the receipt of advances as well as repayment of the same - HELD THAT:- AO after due consideration of the details and information furnished by the writ applicant from time to time, consciously chose not to make any addition in respect of the transactions as to the receipt of ₹ 6 crore as well as the repayment of the same while framing the assessment under Section 143(3) of the Act. Thus, the issue on hand had been minutely scrutinized by the then Assessing Officer at the stage of the original assessment. Now, the respondent is looking forward to touch the very same issue by re-opening the writ applicant’s case which is nothing but change of opinion. The action of re-opening the writ applicant’s case under Section 147 merely based on change of opinion is not tenable in the eye of law. - Decided in favour of assessee.
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