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2022 (4) TMI 1080 - GUJARAT HIGH COURTReopening of assessment u/s 147 - Eligibility of reason to believe - HELD THAT:- Having gone through the materials on record, we are of the view that all the aspects of the matter sought to be relied upon for the purpose of reopening were very much before the Assessing Officer at the time when the scrutiny assessment under Section 143(3) was carried out. To this extent, Mr. Bhatt with his usual fairness conceded. We are of the view that the case is not one of any omission or failure on the part of the writ applicant in fully and truly disclosing all the relevant aspects of the matter. No new tangible material could be said to have come to the knowledge of the respondent after the framing of the assessment. The case could be said to be one of mere change of opinion - Writ application succeeds and is hereby allowed
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