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Assessing Officer Cannot Reopen Completed Assessments u/s 143(3) Due to Change of Opinion.

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....Reopening of assessment - When a regular assessment is completed in terms of Section 143(3), a presumption can be raised that such an order has been passed upon a proper application of mind - what the AO is now seeking to do amounts to a clear change of opinion and that is not permissible - HC....

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