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    <description>The Tribunal dismissed the Departmental appeals, upholding the CIT(A)&#039;s decision that the reassessment proceedings were invalid as they were based on a mere change of opinion and initiated beyond the statutory time limit. The Tribunal found that the assessee had disclosed all material facts during the original assessment and that the AO had considered the issue of deductions under Sections 80HH and 80-I at that time.</description>
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      <description>The Tribunal dismissed the Departmental appeals, upholding the CIT(A)&#039;s decision that the reassessment proceedings were invalid as they were based on a mere change of opinion and initiated beyond the statutory time limit. The Tribunal found that the assessee had disclosed all material facts during the original assessment and that the AO had considered the issue of deductions under Sections 80HH and 80-I at that time.</description>
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