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Re-assessment u/s 147 invalid due to mere change of opinion on Section 10A deduction without new facts.

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....Initiation of the re-assessment proceedings u/s 147 by issuing a notice u/s 148 merely because of the fact that now the AO is of the view that the deduction under Section 10A was allowed in excess, was based on nothing but a change of opinion on the same facts and circumstances - SC....

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