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Revenue Department's Attempt to Reopen Assessment u/ss 147 and 154 Quashed Due to Change of Opinion.

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....Reopening of assessment u/s.147 - revenue department wanted to initiate the proceedings both u/s.147 as well as u/s.154, which itself has established that the information as well as the accounts were very much on record, which were very much in the notice of the AO - on the basis of change of opinion, the AO has not resorted to section 147 - proceedings quashed....