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    <description>Validity of reassessment where a deduction claimed is prohibited under the Income-tax Act was examined; the governing principle is that reopening cannot be justified merely by a change of opinion on the same material, and therefore a reassessment initiated on that basis is invalid and its merits need not be reviewed. The maintainability of a challenge as a substantial question of law was rejected because the jurisdictional parameters for reopening were not satisfied, and consequently no substantial question of law arises for adjudication and the appeal is not maintainable.</description>
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