Reopening of assessment u/s 147 - the learned Single Judge was justified in coming to the conclusion...

Reopening of assessment u/s 147 - the learned Single Judge was justified in coming to the conclusion that the jurisdictional requirements for invocation of Section 147/148 of the Act in the instant case were not satisfied and therefore, the impugned notice was only a case of 'change of opinion' and did not come within the scope and ambit of 'reason to believe'. - HC .....

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