Reopening Denied: Section 10A Deduction Claim Cannot Be Reassessed Due to Change of Opinion After Scrutiny.

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....Reopening of assessment - claim of deduction u/s 10A denied - scrutiny assessment was conducted - It was not be open for the Assessing Officer to reopen such assessment on the principal claim of the petitioner for deduction on the ground that some other elements or aspects of the claim were not examined. This would clearly be a case of change of opinion.....