Validity of reopening of assessment u/s 147 - validity of reason...

Validity of reopening of assessment u/s 147 - validity of reason to believe - during the scrutiny assessment, the case was discussed with the assessee on four dates, prior to which, a questionare containing as many as 13 questions were put to the assessee with direction to file relevant documents and on scrutiny of those documents, the Assessing Officer called for further particulars which had also been furnished by the assessee - the reopening of the assessment is a clear case of change of opinion - HC