Reassessment u/s 147 invalid as reopening based on AO's change of opinion on Section 80IB(10) claim.

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....Reassessment u/s 147 - failure on the part of the petitioner to disclose fully and truly all material facts necessary for its assessment - AO had examined the claim for deduction u/s 80IB(10) in detail, therefore, merely because he did not examine such claim from the angle of clauses (e) and (f) thereof, would not be a valid ground for reopening the assessment - it is mere change of opinion - notice unsustainable....