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2016 (8) TMI 769 - HC - Income TaxRe-opening of assessment - TDS u/s 195 - Held that:- It was only after such detailed scrutiny that the Assessing Officer passed the order of assessment in which he made no additions on the ground of failure to deduct tax at source. It is true that he has not discussed this issue actively in the order of assessment. However, this would not change the position insofar as the question of scrutinizing the issue is concerned. Any attempt on his part to reopen the assessment would thus be on a change of opinion since no fresh or new material has come on record, as can be seen from the reasons recorded in which Assessing Officer referred to ‘having noticed such facts on verification of the records. - Decided in favour of assessee.
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