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Court Rules Reopening of Assessment u/s 148 Invalid Due to Lack of New Evidence, Just a Change of Opinion.
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....Reopening of assessment u/s 148 - ‘review’ and ‘change of opinion’ - The respondent has failed to show why the presumption should not be applied in the present case. It can also be seen from the reasons recorded that there was no new material which had come to the notice of the AO and the entire reference in the reasons recorded is only to the material on record. - HC....