Reassessment Invalid: No Assessee Disclosure Failure u/ss 147 & 148; Original Assessment Had No Errors.

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....Re-assessment u/ss 147 / 148 - no failure on the part of the Assessee to disclose fully and truly the relevant material resulting in such escapement of income in the form of either excess deductions or some additions or deductions u/s 36(1) - there is nothing on record to show that there was non-application of mind on the part of the AO in original assessment u/s 143(3) - reassessment not valid as it is mere case of change of opinion....