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Income Tax - Highlights / Catch Notes

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Reopening of assessment u/s 147 - The reasons recorded for ...


Reassessment u/s 147 Challenged: No New Evidence, Just a Change of Opinion by Assessing Officer.

August 31, 2022

Case Laws     Income Tax     AT

Reopening of assessment u/s 147 - The reasons recorded for reopening the assessment contain ample proof in itself to show that there was no new material in the possession of the Ld. AO. He scrutinized the same documents which were already available on records for seeking to reopen the assessment which, in our view, amounts to re-appraisal of the same facts and change of opinion. - AT

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