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2022 (10) TMI 365 - SUPREME COURTReopening of assessment u/s 147 - Addition u/s 68 - Unexplained share capital HELD THAT:- Considering the fact that earlier the AO had called upon the petitioner(s) to produce the evidence in support of increase of authorised share-capital, produce the evidence of share allotment and names and addresses of the parties from whom share-premium was received, among other things and thereafter, the AO finalised the assessment and passed Assessment Order, the subsequent re-opening can be said to be change of opinion. Under the circumstances, the re-opening is rightly set aside by the High Court. We see no reason to interfere with the same. Special Leave Petition stands dismissed.
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