Bench: Shri Vijay Pal Rao & Shri B.M. Biyani
disallow the said claim without any new facts or record is not permissible being change of opinion. Hence, we hold that the reopening of the assessment is not valid and the same is quashed. Since the reopening of the assessment is quashed therefore, the issues raised by the assessee on merits becomes infructuous. 6. For A.Y.2009-10 the assessee has raised