Introducing the “In Favour Of” filter in Case Laws.
- ⚖️ Instantly identify judgments decided in favour of the Assessee, Revenue, or Appellant
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Introducing the “In Favour Of” filter in Case Laws.
Try it now in Case Laws →
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of Reopening of assessment u/s 147 - Reasons to belive - change of opinion - there was no new material which had come to the notice of the Assessing Officer and the entire reference in the reasons recorded is only to the material on record. - issue with regard to depreciation had been gone into by the said AO without making any disallowance as regards the claim of the depreciation - the reassessment proceedings were nothing but a case of ‘change of opinion’, which does not comply with the jurisdictional foundation under section 147 - HC
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