https://www.taxtmi.com/caselaws?id=242737 The Tribunal dismissed the Revenue's appeal against the order of the First Appellate Authority, upholding that the reopening of assessment under section 147 was impermissible as it constituted a mere change of opinion and was not valid in law. The Tribunal emphasized that a retrospective change in legal position does not justify reopening assessments finalized under the law prevailing at the relevant time. The decision was based on legal principles and precedents, including the jurisdictional High Court's binding judgment, highlighting that a change of opinion does not warrant reassessment. en-us Fri, 19 Jul 2013 00:00:00 +0530 Sun, 19 Jan 2014 09:50:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=242737 The Tribunal dismissed the Revenue's appeal against the order of the First Appellate Authority, upholding that the reopening of assessment under section 147 was impermissible as it constituted a mere change of opinion and was not valid in law. The Tribunal emphasized that a retrospective change in legal position does not justify reopening assessments finalized under the law prevailing at the relevant time. The decision was based on legal principles and precedents, including the jurisdictional High Court's binding judgment, highlighting that a change of opinion does not warrant reassessment. Case-Laws Income Tax Fri, 19 Jul 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=242737