High Court Rules Reopening of Assessment Invalid u/s 147 Due to Change of Opinion, No Undisclosed Facts Found.

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....Validity of Reopening of assessment u/s 147 - change of opinion - Onus to prove - Not only material facts were disclosed by petitioner truly and fully but they were carefully scrutinized and figures of income as well as deduction were reworked carefully by the AO - In the reasons for reopening, there is not even a whisper as to what was not disclosed. In our view, this is not a case where the assessment is sought to be reopened - HC....