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    <title>1996 (10) TMI 63 - PUNJAB AND HARYANA High Court</title>
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    <description>The Tribunal held that the reassessment for the assessment year 1970-71 under section 147(a) of the Income-tax Act was impermissible and unsustainable. Despite a third party disputing cash credits, the assessee had fully disclosed all material facts during the original assessment. The Income-tax Officer&#039;s attempt to reopen the assessment based on new evidence was deemed unauthorized as it amounted to a change of opinion, which is not permissible under the law. The Tribunal rejected the Revenue&#039;s claim for a referable question of law and denied costs, affirming that the reassessment was unjustified.</description>
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