Reopening of Assessment not permissible to take another view on same material

Vodafone Idea Ltd. Vs ACIT (Bombay High Court)

The entire basis for proposing to reopen, as can be seen from the reasons, is on the documents and submissions which were available before the Assessing Officer, before passing of the original assessment order. In fact, in the reasons, it is also recorded that the same issue was considered by the earlier Assessing Officer during the assessment proceedings.

The Assessing Officer notes that the assessee had made submissions on these items earlier but still states that incom

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