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of Reopening of assessment u/s 147 - The fact that the Assessment Order does not contain any reference or discussion relating to depreciation claimed by petitioner on the goodwill that it had paid while applying the shares of ETPL would mean that the query raised was considered by the A.O. while completing the assessment and the A.O. was satisfied with the explanation offered in respect of the query raised. - It is merely change of opinion - Notice quashed - HC
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