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2005 (3) TMI 30 - DELHI HIGH COURTReassessment - "Whether Tribunal was justified in law in holding that the Income-tax Officer assumed jurisdiction under section 147(b) of the Act merely on a change of opinion?" - This is nothing but a mere change of opinion which is not permissible for reopening an assessment. It was not the case of the Income-tax Officer that the information was not available at any point of time. Consequently, the Income-tax Officer had seen the material on record and he would have found it difficult to reopen the assessment under section 147(b) of the Act on the same material. We are of the view that on the above facts and position in law, there is no reason to differ with the view taken by the Income-tax Appellate Tribunal. Accordingly, we answer the reference in the affirmative, in favour of the asses-see and against the Revenue
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