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of <h1>Validity of reopening of assessment: reassessment challenged as change of opinion with delayed reasons, petition dismissed.</h1> Reopening of assessment was analysed on whether the tax authority acquired new material or merely altered its opinion based on the same facts; the High ... Validity of Reopening of assessment u/s 147 - eligible reason to believe - change of opinion - Non furnishing of reasons within reasonable time - whether new facts coming to the knowledge of the Assessing Officer subsequent to the original assessment proceedings? - HC held assessment proceedings, having been done with the same set of facts which were available during the regular assessment, is to be held to be a clear case of change of opinion and reasons were not furnished to the assessee within a reasonable time - HELD THAT:- In view of the findings recorded by the High Court in re questions raised and answers given, before, the assessment order under Section 143(3) of the Income Tax Act, 1961 was passed, we are not inclined to issue notice in the present special leave petition. The assessee has no role to play and is not the author of the assessment order and hence the manner and contents of the assessment order as framed is not determinative whether or not it is a case of change of opinion. Recording the aforesaid, the special leave petition is dismissed. The Supreme Court of India dismissed the special leave petition as the assessee has no role in the assessment order under Section 143(3) of the Income Tax Act, 1961. The delay was condoned, and pending applications were disposed of.
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