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2023 (8) TMI 1077 - HC - Income TaxReopening of assessment u/s 147 - Reopening beyond period of four years - Change of opinion - as observed that on scrutiny of profit and loss account, balance sheet, computation of income, it was found that the assessee had claimed and allowed deduction u/s 80- IA - HELD THAT:- The petitioner had truly and fully disclosed all the material facts which were called upon by the revenue at the relevant time. The reopening of the assessment is nothing but a mere change of opinion on the part of AO. If the AO could not discover even with due diligence, the petitioner cannot be blamed for that. If the AO did not examine the issue of allowability of the deduction during the course of regular assessment, the revenue has no jurisdiction to reopen the assessment. Decided in favour of assessee.
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