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Reopening Tax Assessment u/s 147 Not Justified if Based Solely on Change of Opinion After Full Disclosure.
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....Reopening of assessment u/s 147 - Change of opinion - Once the assessee makes a true and full disclosure of the primary facts at the time of the original assessment and which could have been discovered with due diligence by the Income Tax Officer, drawing an inference which appears subsequently to be alone, is a mere change of opinion - HC....