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The taxpayers shall be reminded of the fact the power to reopen is a very powerful tool and the same is required to be exercised in accordance with law and not otherwise. 


In [2022] 447 ITR 357 (Mad) the tax officer exercised such power alleging that the claim made by the assessee in original assessment under section 37 was incorrect and the expenditure was in the nature referred to in section 35D so that the Court held it as a mere change of opinion and beyond his jurisdiction. The Court further declined remand in this case.

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