Reopening on ground of oversight, inadvertence or mistake is invalid

The grievance of the Revenue with regard to the impugned order so far as change of opinion is concerned, is that the Assessing Officer had acted upon on audit objection which has been received by him. Thus, there was tangible material available for issuing notice for reopening of the assessment. It is further submitted that merely because the Assessing Officer does not deal with a particular issue in the original assessment proceedings, it would not prohibit the Revenue from issuing reopening, otherwise provisions of Section 147 and 148 would be rendered redunda

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