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The Delhi High Court dismissed the revenue's appeal against the Income-tax Appellate Tribunal's order regarding the reopening of assessment for the assessment years 1998-99 and 2001-02. Both the Commissioner of Income-tax (Appeals) and the Tribunal found the reopening to be a change of opinion, as the assessee had disclosed relevant facts. The Tribunal cited a previous court decision in its ruling, leading to the dismissal of the appeal.
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