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2020 (1) TMI 1061 - HC - Income TaxReopening of assessment u/s 147 - mere change of opinion - HELD THAT:- Petitioner has raised several contentions touching upon the merits of the notice issued u/s 148 including the limitation and also by contending that it is based on change of opinion, but these contentions cannot be considered at this stage now, since the petitioner is bound to give objections to the reasons for reopening and thereafter, AO has to pass a reasoned order, as observed by the Apex Court in "GKN Driveshafts (India) Ltd. case [2002 (11) TMI 7 - SUPREME COURT] . When such course of action is yet to be completed, these writ petitions at this stage can be maintained any further. Therefore, without expressing any view on the merits of the contentions raised by the petitioner against the impugned notice, these writ petitions are disposed of, by granting liberty to the petitioner to give objections to the reasons for reopening, within a period of four weeks from the date of receipt of a copy of this order. On receipt of such objections, the Assessing Officer shall consider the same and pass a reasoned order, within a period of four weeks thereafter.
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