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of Reopening of assessment - change of opinion - Even de hors any additional explanation by Petitioner, the wording and language of the notice and the order impugned herein itself reveals the distinct views taken by the AO. We find that the reopening of assessment is merely based on a change of opinion on the same set of facts and material before the AO which was available to him at the time of original assessment. - The order and notice quahsed - HC
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