Reopening of Assessment u/s 147 Valid; Petitioner Failed to Deduct TDS, Not a Change of Opinion.

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....Reopening of assessment u/s 147 - eligible reasons to believe - In the instant case, as stated by the respondent in the affidavit-in- reply, the petitioner had not deducted the TDS as detailed in Annexure 6 to form 3CD and therefore, the same was not taken into consideration by the Assessing Officer while passing the order under Section 143(3) of the Act. When the said material was not considered at the time of original assessment on 30.12.2016, the consideration of the same by the respondent could not be said to be a change of opinion or review of earlier order. - HC....