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Reassessment u/s 147 Invalid Due to Change of Opinion, No New Material Justifying Reopening Found.

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....Reassessment u/s 147 - original order u/s 143(3) - once finding of fact recorded that no new material has surfaced on the basis of which the assessment proceedings could be reopened, the reopening was clearly on account of change of opinion by the AO which is not permissible under the scheme of the Act....

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