Reopening of assessment u/s 147 - reasons to believe - The High...

Reopening of assessment u/s 147 - reasons to believe - The High court observes that all the issues raised in the notice for reopening were indeed subject to discussion during the assessment proceedings. Despite the absence of explicit mention in the assessment order, the court holds that the Assessing Officer had considered the petitioner's submissions on these matters. As a result, the court concludes that the reopening of the assessment is merely based on a change of opinion, which does not constitute a valid reason to believe that income has escaped assessment.