Court Quashes Reopening of Assessment; AO's Notice u/s 148 Invalid Due to Mere Change of Opinion.

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....Reopening of assessment - AO seeks to reopen the assessment on a mere change of opinion inasmuch as, at the time of scrutiny assessment, AO had applied his mind to the issue and even recorded finding in respect thereof in the assessment order framed u/s 143(3) - Notice issued u/s 148 quashed.....