No reassessment to change calculation method under rule 8D in lack of any failure on part of assessee in furnishing doc.

INCOME TAX : Reopening of assessment beyond four years on ground that expenditure in relation to income not includible in total income under section 14A should have been calculated as per clause (ii) of rule 8D(2) would amount to change of opinion when no negligence was found on part of assessee in furnishing necessary materials for completing assessment under section 143(3)

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