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The action of re-opening the writ applicant’s case under Section 147 merely based on change of opinion is not tenable in the eye of law.

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Section 143(3),147&148 of the Income tax Act, 1961 — Reassessment — Information was furnished by assessee in respect of transactions and was considered by AO in original assessment, thus, reopening of assessment on same issue amounts to change of opinion and was untenable — Rajendra Suganchand Shah vs. Assistant Commissioner of income tax [2019] 417 ITR 583 (Gujarat)

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