No reassessment on basis of change of opinion that assessee had claimed higher amount of exemption u/s 10B

IT: In absence of any failure on assessee's part to disclose fully and truly all material facts necessary for assessment, reassessment proceedings could not be initiated after expiry of four years from end of relevant year, merely on basis of change of opinion of AO that due to disproportionate bifurcation of expenditure between eligible and non-eligible units, higher amount of exemption was claimed under sec. 10B in respect of profits earned by eligible industrial undertaking

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