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2021 (4) TMI 738 - ITAT KOLKATAReopening of assessment u/s 147 - re-opening is beyond the period of four years - HELD THAT:- It is a clear case of change of opinion and hence the re-opening of assessment based on mistake of opinion is bad in law. Even otherwise the re-opening is beyond the period of four years and the original assessment was completed u/s 143(3) of the Act on 08.12.2011. In the reasons recorded, there is no whisper that the assessee has failed to disclose truly and fully all material facts required for assessment. In the absence of such an allegation the reopening is bad in law as the proviso to Section 147 comes into play. - Decided in favour of assessee.
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