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2021 (11) TMI 58 - HC - Income TaxReopening of assessment u/s 147 - Eligibility of reasons to believe - change of opinion - HELD THAT:- In the facts of the present appeal a query was raised by the Assessing Officer in original assessment in respect of waiver of loan on account of One Time Settlement with the banks and assessee had filed detailed submission as to why principal amount was waived by the bank on account of One Time Settlement is not taxable. Once there was query raised with regard to a particular issue during regular assessment proceedings it must follow that the Assessing Officer had applied his mind and taken a view in the matter as reflected in the assessment order. See Aroni Commercials Ltd. vs. Assistant Commissioner of Income Tax - [2014 (2) TMI 659 - BOMBAY HIGH COURT] - Decided in favour of assessee.
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