Reassessment u/s 147 Challenged: AO's Change of Opinion on Business Loss as Speculation Loss Deemed Invalid.

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....Reopening of assessment u/s 147 - In the reasons for reopening, AO has not nowhere indicated that the business loss suffered by the assessee can be treated speculation loss and only in the revised assessment order, AO came to the conclusion that this loss can only be speculation loss. - the re-assessment order is only a change of opinion.....