https://www.taxtmi.com/caselaws?id=262563 The SC held that the reopening notice issued under sections 143 and 147 was valid despite the return being accepted under section 143(1), as no opinion was formed at that stage, negating the concept of change of opinion. The Court affirmed that if the conditions of section 147 are met, the Assessing Officer may initiate reassessment proceedings regardless of prior acceptance under section 143(1) or failure to act under section 143(3). The HC's decision allowing the assessee's appeal was set aside, and the appeal was allowed in favor of the revenue. en-us Fri, 17 Apr 2015 00:00:00 +0530 Sat, 26 Jul 2025 10:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=262563 The SC held that the reopening notice issued under sections 143 and 147 was valid despite the return being accepted under section 143(1), as no opinion was formed at that stage, negating the concept of change of opinion. The Court affirmed that if the conditions of section 147 are met, the Assessing Officer may initiate reassessment proceedings regardless of prior acceptance under section 143(1) or failure to act under section 143(3). The HC's decision allowing the assessee's appeal was set aside, and the appeal was allowed in favor of the revenue. Case-Laws Income Tax Fri, 17 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=262563