High Court Rules Reopening of Tax Assessment Invalid Due to Incorrect Section Claim by Assessing Officer.

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....Reopening of assessment - Re-opening is on the basis of gross incorrect facts that the assessment had been completed u/s 143(1) of the Act of 1961 and was hence no assessment u/s 2(40) of the Act of 1961 when infact the assessment had been completed u/s 143(3) - re-opening was thus merely an outcome of change of opinion of the AO - HC....