Reopening notice beyond 4 years quashed. Complete details submitted, no non-disclosure. Mere change of opinion.

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....Reopening of assessment notice beyond four-year period quashed. Assessee submitted complete details for section 80IA deduction claim with return. No failure to disclose material facts. Reasons for reopening amounted to mere change of opinion without live link to material. Assessing Officer examined section 80IA claim in detail during original assessment proceedings. Reopening notice unsustainable beyond four years. Decided in assessee's favor.....