Reopening of assessment u/s 147 - Material, which was already placed on record, and considered in...

Reopening of assessment u/s 147 - Material, which was already placed on record, and considered in earlier two rounds of litigation can hardly be a reason to reopen the assessment and all that we can say is that the attempt of the Department is to reopen a settled issue solely based upon change of opinion. The Department is silent and has not disclosed as to what is the tangible material, which is now available with them more than those that were available with the Department in the earlier two r..... .....

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