TMI BlogValidity of reopening of assessment u/s 147 - Proof of new material to justify the re-opening of the...Validity of reopening of assessment u/s 147 - Proof of new material to justify the re-opening of the assessment - change of opinion - there was conscious application of mind by the AO to the said materials. Therefore, the inevitable conclusion as far as the present case is concerned is that the ‘reason to believe’ of Opposite Party No.1 that income for the AY in question had escaped assessment is based on a mere ‘change of opinion’ - HC ..... X X X X Extracts X X X X X X X X Extracts X X X X
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