Assessment Reopening Challenged: Audit Objection and Change of Opinion u/s 147 Lacked Independent Evaluation by Officer.

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....Reopening of assessment u/s 147 - Reopening based on audit objection and also change of opinion - the reasons recorded in the present case are verbatim what the audit objection is - It means that the AO has not applied his independent mind to the facts of the case before recording reasons - AT....