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of Reopening of assessment u/s 147 - The writ-applicant has claimed deduction under Section 35(1)(ii) of the Act and not under Section 80GGA of the Act. This fact is also disclosed by the assessee in the revised return. - When there is no failure on the part of the petitioner-assessee to disclose, truly and fully, material facts, the Assessing Officer cannot reopen the assessment on the basis of “mere change of opinion”, as there is no tangible material to come to the conclusion that there is escapement of income from assessment. - HC
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