Reopening by change of opinion on facts already examined is not valid

Vapi Infrastructure and Industrial Township LLP Vs ITO (Bombay High Court)

Petitioner vide a letter dated 21^st October, 2021 filed its objection for re-opening. In the objection, Petitioner specifically has mentioned that specific queries were raised during assessment proceedings for the loans provided, details have been provided to the assessing officer who had also independently issued notices under Section 133(6) of the Act to which third parties had replied and provided the required documents explaining their

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