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Reassessment Notice u/s 148 Invalid Due to Lack of New Evidence; Based on Opinion Change Only.

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Full Text of the Document

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....Reopening of assessment - The assessment order makes it very clear that reassessment proceedings by issuing notice u/s 148 were done merely on the basis of change of opinion. There was no tangible material to arrive at a conclusion that there was escapement of income by the assessment.....

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