2023 (8) TMI 1308

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..... 22 (4) TMI 624 - BOMBAY HIGH COURT] reopening of assessment by the impugned notice dated 31.03.2021 is merely on the basis of change of opinion of the AO from that held earlier during the course of assessment proceedings. HELD THAT:- There is an inordinate delay of 382 days in filing this special leave petition which has not been satisfactorily explained. Even on merits, we do not find any goo .....

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