Reopening of Tax Assessment u/s 147 Deemed Invalid Due to Change of Opinion; Rules 9A and 9B Misapplied.

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....Reopening of assessment u/s 147 - escapement of income determined by applying Rule 9A & 9B of Income Tax Rules, 1962, which deals with quantification of expenses allowable in case of film producer and distributor - reasons recorded by the Assessing Officer for reopening of assessment is a clear case of change of opinion, which is not permissible under the law - AT....