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Income Tax - Highlights / Catch Notes

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Reopening of assessment u/s 147 - Reason to believe - change of ...

Case Laws     Income Tax

October 5, 2023

Reopening of assessment u/s 147 - Reason to believe - change of opinion - The reason we say that there is a change of opinion is because once a query has been raised during the assessment and query has been answered and accepted by the AO while passing the assessment order, it follows that the query raised was a subject of consideration of the AO while completing the assessment. This would apply even if the assessment order has not specifically dealt with that issue. - HC

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