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2019 (9) TMI 2 - AT - Income TaxReopening of assessment u/s 147 - reopening after four years - HELD THAT:- As decided in FORAMER FRANCE [2003 (1) TMI 101 - SC ORDER] admittedly no failure on the part of the assessee to make a return or to disclose fully and truly all material facts necessary for the assessment. Hence, the proviso to the new section 147 squarely applies, and the impugned notices were barred by limitation mentioned in the proviso Although we are of the opinion that the law existing on the date of the impugned notice under section 147/148 has to be seen, yet even in the alternative even if we assume that the law prior to the insertion of the new section 147 will apply, even then it will make no difference since even under the original section 147 notice for reassessment could not be given on the mere change of opinion as held in numerous cases - Decided in favour of assessee.
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