2025 (2) TMI 198

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... IGH COURT] reasons recorded to believe that there is escapement of income from assessment does not even make an allegation that there was failure to truly and fully disclose material fact. reopening of assessment is merely based on the basis of change of opinion as applicability of Section 73 of the Act was a subject of consideration during the assessment proceedings HELD THAT:- We do not find an .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X