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2023 (2) TMI 862 - DELHI HIGH COURTReopening of assessment u/s 147 - addition u/s 68 - tribunal sustained the deletion of addition - HELD THAT:- None of the findings of the fact recorded by the Tribunal have been assailed before us. We have no difficulty in agreeing with the Tribunal that the respondent/assessee was put to scrutiny with regard to the infusion of share capital and had furnished the relevant information sought by the AO when the initial assessment order was framed under Section 143(3) of the Act. The Tribunal, therefore, was right in reaching the conclusion that this was a case of change of opinion, and therefore, the first proviso to Section 147/148 was applicable, the pre-requisites of which having not been fulfilled, re-assessment proceedings could not have been triggered. For the foregoing reasons, we are not inclined to interdict the order passed by the Tribunal. No substantial questions of law.
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