TMI Blog2023 (12) TMI 589X X X X Extracts X X X X X X X X Extracts X X X X ..... capital reduction in the balance sheet - capital gain transactions filed under Schedule C.G. - Capital Gains - purchase and sale of shares and the conversion of amounts in foreign currency - petitioner categorically mentioned that it had not carried on any business activity since the liquidation/bankruptcy application and also mentioned about the capital reduction - petitioner had incorrectl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ny failure to disclose facts by the assessee or any tangible new material, the reopening of assessment proceedings by the respondent is bad in law. The reopening of the assessment based on a different method of computation or application of the section is nothing else but a change of opinion, which is impermissible in law and allowed assessee appeal - HELD THAT:- SLP dismissed. - HON'BL ..... X X X X Extracts X X X X X X X X Extracts X X X X
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