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Income Tax - Highlights / Catch Notes

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Reopening of assessment u/s 147 - Change of opinion - TP ...

Income Tax

February 17, 2022

Reopening of assessment u/s 147 - Change of opinion - TP adjustment addition - Courts have repeatedly held that once a query is raised and that has been explained by the assessee, even if there is no discussion on that aspect in the assessment order still the Assessing Officer is deemed to have consider these points and applied his mind. - All these only indicate one thing that re-opening is proposed on the basis of change of opinion. - HC

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