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2022 (1) TMI 542 - HC - Income TaxReopening of assessment u/s 147 - Eligibility of reason to believe - change of opinion - claim of deduction u/s 80IB(10) - HELD THAT:- Assessment Officer has no power to review an assessment which has been concluded. AO before he passed the assessment order, had in his possession all primary facts necessary for assessment and then he made the original assessment. When the primary facts necessary for assessment are fully and truly disclosed, the Assessing Officer is not entitled on change of opinion to commence proceedings for reassessment. Where on consideration of material on record, one view is conclusively taken by the Assessing Officer, it would not be open to reopen the assessment based on the very same material with a view to take another view - See ANANTA LANDMARK PVT. LTD. [2021 (10) TMI 71 - BOMBAY HIGH COURT]. We are satisfied that not only material facts were disclosed to the petitioner truly and fully, but they were carefully scrutinized and figures of income as well as deduction were viewed carefully by the Assessing Officer. - Decided in favour of assessee.
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