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of Validity of reopening of assessment u/s 147 - reasons to believe - increase in share capital - There was no allegation that there is any failure on the part of the assessee, i.e., the petitioner to truly and fully disclose the material facts, and further the reopening is sought on the basis of verification of record, and as such, there was no fresh tangible material distinct from what was available at the time of assessment proceedings - The notice of reopening quashed and set aside. - HC
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