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Reopening of assessment u/s 147 - eligibility of reasons to believe - change of opinion - nowhere AO has...

Reopening of assessment u/s 147 - eligibility of reasons to believe - change of opinion - nowhere AO has been able to make out a case that there was any omission or failure on the part of the petitioner to disclose fully and truly the necessary material facts - if at all there was any clerical/arithmetical mistake apparent from record then recourse was available to the assessing officer by way of rectification under Section 154 of the Income Tax Act, 1961 and that cannot be a ground of reopening..... .....

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