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2022 (12) TMI 802 - HC - Income TaxReopening of Assessment u/s 147 - change of opinion - Reopening permissible if the assessee had not disclosed all the relevant particulars fully and truly before the assessing officer - reopening on a standalone basis - disallowing the claim towards debiting to the profit & loss account due to reversal on account of cancellation and price revision - HELD THAT:- The fact that the reopening of assessment was ordered on mere change of opinion has been upheld by two lower appellate authorities. It is evident that respondent had disclosed fully and truly all material facts to the assessing officer during the assessment proceeding on the basis of which assessment order was passed u/s 143(3) of the Act. By change of opinion holding that reduction towards reversal on account of cancellation and price revision and deducting the same from the profit and loss account was irregular thereby having reason to believe that taxable income had escaped assessment, the concluded assessment could not have been reopened. At the stage of third round of appeal we do not find any substantial question of law for interference by the High Court under Section 260A - We are, therefore, of the view that there is no merit in this appeal. - Decide against revenue.
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