No reassessment beyond 4 years on issue already dealt during original assessment

Saurabh Natvarlal Soparkar Vs ACIT (Ahmedabad High Court)

it is evident that a specific query was raised by the Assessing Officer with respect to Section 14A and the same was appropriately replied by the writ applicant. The same was accepted at the relevant point of time. Once again the very same issue is sought to be raised for the purpose of reopening which is otherwise not permissible in law on mere change of opinion. It cannot be said that there was any failure on the part of the assessee to fully and truly disclose all

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