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https://taxcharcha.com/the-reopening-of-assessment-is-an-entirely-independent-and-vastly-different-jurisdiction-and-cannot-be-confused-with-the-revisional-powers-of-the-higher-authority-bombay-high-court/
The Reopening of assessment is an entirely independent and vastly different jurisdiction and cannot be confused with the revisional powers of the higher authority - Bombay High Court