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SARADBHAI M. LAKHANI versus INCOME-TAX OFFICER


There is no ground for evaluating change in the assessment officer's opinion that has gone beyond the assessment of income. No reference can be made to the High Court decision in the form of an affidavit in reference to the recorded reasons for re-examination. Such income was not appropriately based on the change of opinion, the Indian Income Tax Act, 1961, Sections 147 and 148.

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