AO cannot act u/s. 147 merely because he happened to change his opinion or to hold an opinion different from that of his predecessor on same set of facts

 ITAT, MUMBAI BENCH `K’, MUMBAI,

Audco India Ltd. Vs ITO, A

APPEAL NO: ITA No. 6305/M/2007,

DECIDED ON April 22, 2010

RELEVANT PARAGRAPH

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