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of Reopening of assessment u/s 147 - Case of the petitioner is not falling within the proviso Clause (c) of explanation 2 to Section 147 of the Income Tax Act and the respondents could not able to establish that there was a failure on the part of the Assessee to disclose fully and truly all material facts and further, this Court could able to arrive a conclusion that the factual inference drawn is also change of opinion, the petitioner is entitled to succeed in the present case. - HC
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