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        Case ID :
        Income Tax

        Reopening of assessment u/s 147 - True and full disclosure of...

        Challenge to Assessment Reopening: Section 147 Cited for Change of Opinion and True Disclosure of Facts in Tax Case.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                Reopening of assessment u/s 147 - True and full disclosure of all material facts - It is true that in the assessment order self-disallowances have not been discussed but at the same time it has been a subject of consideration during the assessment proceedings since the Assessing Officer has started from the business income as returned by petitioner, which included self-disallowances debited to the P&L Account. - it is a clear case of change of opinion to take a different view relying on the same set of documents. Change in opinion cannot construe “reason to believe”. - HC
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