Reopening of assessment challenged for change of opinion and nondisclosure; HC issued notice and restrained final order.

Reopening of assessment was challenged on the grounds of change of opinion and absence of any failure to disclose fully and truly all material facts. The HC issued notice, permitted the respondent to proceed further under the impugned notice, but restrained it from passing the final order without the Court's permission.

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Issues: Challenge to reopening of assessment on the grounds of change of opinion and absence of failure to disclose fully and truly all material facts.

Outcome: Notice issued. The respondent is permitted to proceed further pursuant to the impugned notice, but shall not pass the final order without permission of the Court.

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