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of Reassessment notice u/s 148 - in pursuant to notice u/s 142(1), petitioner had furnished complete details with various documentary evidence and case was discussed by the ITO - It cannot be said that the tangible material which is said to have come to the notice of the AO was not taken into consideration and the income chargeable to tax have escaped assessment - reopening on the basis of the very same material, is change of opinion - notice quashed
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