Reopening of Assessment Ruled Invalid Due to Lack of New Evidence and Failure to Allege Non-Disclosure of Material Facts.

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....Validity of reopening of assessment - The High court observed that the reasons for reopening did not specifically allege any failure on the part of the petitioner to disclose all material facts. Moreover, the issues raised were already considered during the original assessment proceedings. Therefore, the reopening based on a change of opinion was not justified.....