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2006 (6) TMI 163 - AT - Income TaxExtract: .......R (Del)(FB) 617 (2002) 256 ITR 1 (Del)(FB). In view of the above discussed legal position, we are satisfied that the learned CIT(A) rightly appreciated the facts by holding it to be a case of change of opinion and quashed the reassessment proceedings. We, therefore, uphold the impugned order on this score. 4. In the result, the appeal is dismissed.
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