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Reopening of assessment - AO has no power to review; he has the power to re-assess. But re-assessment has to be based on fulfillment of certain pre-condition and if the concept of change of opinion is removed as contended on behalf of the Department thenin the garb of re-opening the assessment review would take place - to reopen an assessment tangible material should be there - HC

Income Tax - Reopening of assessment - AO has no power to review; he has the power to re-assess. But re-assessment has to be based on fulfillment of certain pre-condition and if the concept of change .....

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