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2020 (1) TMI 815 - AT - Income TaxReopening of assessment u/s 147 - Bogus purchases - HELD THAT:- CIT(A) considering the submission of the assessee and taking note of the fact that the assessment was completed u/s. 143(3) of the Act originally and during the course of such assessment proceedings assessee has filed all the relevant details in respect of set off of unabsorbed losses and depreciation relating to amalgamating company and also furnished copy of the High Court order approving the scheme of amalgamation, Ld. CIT(A) held that reopening was done merely on change of opinion and not based on any material on record which has come subsequent to completion of the assessment u/s. 143(3) We do not see any valid reason to interfere with the findings and the decision in holding that the reassessment was made merely on change of opinion and quashing the reopening of assessment. None of the findings of the Ld. CIT(A) have been rebutted with evidences by the revenue. Thus, we sustain the order of the Ld.CIT(A) and reject the grounds raised by the revenue.
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