2023 (7) TMI 416

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..... thereof, would not be a valid ground for reopening the assessment as it would amount to a mere change of opinion . HELDTHAT:- In terms of Circular No. 17/2019 dated 08.08.2019 issued by Government of India, Ministry of Finance, Department of Revenue, Central Board Direct Taxes, Judicial Section, since the amount of tax involved is low, we are not inclined to interfere with the impugned order. .....

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