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Reassessment Blocked: All Facts Disclosed, AO's Reopening Deemed "Change of Opinion", Explanation 1 Not Applicable.

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....Reopening of assessment - Explanation 1 would not apply as all primary facts were disclosed, stated and were known and in knowledge of the Assessing Officer. Further, this would be a case of ‘ change of opinion’ as the assessee had disclosed and had brought on record all facts.....

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