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of The Calcutta High Court examined the validity of reassessment proceedings u/s 147 based on change of opinion regarding the assessee's liability u/s 115JB. The Court found that the original assessment order u/s 143(3) did not address the assessee's tax liability u/s 115JB, indicating a non-speaking and cryptic order. Therefore, the reassessment was not a change of opinion but a valid exercise of power u/s 147. The Court held the ITAT's finding on change of opinion as unsustainable. The ITAT's failure to address the revenue's appeal on the escaped income was noted. The decision favored the revenue.
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