Reassessment u/s 147 invalid due to missed notice deadline and change of view on business income.

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....Reopening of assessment u/s 147 - Entire proceedings were based on the change of view. Further, having entertained a view as early as 05.02.2014 that amount was a business income, the respondent ought to have issued the notice on or before 31.03.2014. Instead, the respondent waited till 31.03.2016 to issue notice to the petitioner. Therefore, the impugned order cannot be sustained....