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Income Tax - Highlights / Catch Notes

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Reopening of assessment u/s 147 - True and full disclosure of ...

Income Tax

February 24, 2022

Reopening of assessment u/s 147 - True and full disclosure of all material facts - It is true that in the assessment order self-disallowances have not been discussed but at the same time it has been a subject of consideration during the assessment proceedings since the Assessing Officer has started from the business income as returned by petitioner, which included self-disallowances debited to the P&L Account. - it is a clear case of change of opinion to take a different view relying on the same set of documents. Change in opinion cannot construe “reason to believe”. - HC

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