Reopening an assessment due to change of opinion is invalid if covered u/ss 143(3) or 263 of Income Tax Act.

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....Validity of Reopening of assessment - change of opinion - If the very same reasons were the subject matter of the proceedings under Section 143(3) of the Act or the proceedings under Section 263 of the Act, once again, for the very same reasons, the power under Section 147 cannot be invoked and having done so, the CIT(A) as well as the Tribunal were right in coming to the conclusion that the reopening was bad in law.....