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2005 (8) TMI 79 - HC - Income TaxPetitioners are challenging the for reopening of the assessment u/s 148 - reopening of the assessment on the ground that there is failure on the part of the assessee to disclose fully and truly all material facts cannot be sustained. Reopening on the basis of change of opinion is not permissible. Since the notices themselves are based on the material supplied by the petitioner at the time of initial assessment along with its returns of income, it was not open for the Assessing Officer to reopen the assessment for the assessment years in question - notices in question are quashed and set aside holding them to be bad and illegal.
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