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of The High Court addressed the issue of reopening assessment due to disallowance of depreciation and reduced returned loss. The notice was issued after the 4-year period, leading to a challenge. The ITAT deemed the reopening as a change of opinion, thus invalid. The Court found that the assessing officer lacked tangible evidence for the reassessment and that the assessee had disclosed all necessary facts. Relying on the Kelvinator of India case, the Tribunal's decision was upheld in favor of the assessee.
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