https://www.taxtmi.com/caselaws?id=214603 The Tribunal upheld the CIT(A)'s decision, dismissing the Revenue's appeal on the validity of reopening the assessment under section 147. It emphasized that the reassessment was a change of opinion and not valid, as the Assessing Officer had already considered the relevant facts before issuing the notice under section 148. The Tribunal also agreed with the assessee that assessments cannot be reopened solely on the basis of a change of opinion, citing various High Court decisions. en-us Tue, 29 May 2012 00:00:00 +0530 Tue, 03 Jul 2012 14:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=214603 The Tribunal upheld the CIT(A)'s decision, dismissing the Revenue's appeal on the validity of reopening the assessment under section 147. It emphasized that the reassessment was a change of opinion and not valid, as the Assessing Officer had already considered the relevant facts before issuing the notice under section 148. The Tribunal also agreed with the assessee that assessments cannot be reopened solely on the basis of a change of opinion, citing various High Court decisions. Case-Laws Income Tax Tue, 29 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=214603