TMI Blog2024 (10) TMI 208X X X X Extracts X X X X X X X X Extracts X X X X ..... OURT] action of reopening by the AO was bad in law, mainly for the reason that it was passed on a mere change of opinion on the same set of facts, which was disclosed and considered by the assessing officer during previous AY - HELD THAT:-There is gross delay of 489 days in filing this Special Leave Petition. The reasons assigned for explaining the said delay are neither satisfactory nor sufficien ..... X X X X Extracts X X X X X X X X Extracts X X X X
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