https://www.taxtmi.com/caselaws?id=178881 The tribunal found that the reopening of the assessment under section 147 was invalid as it was based on a mere change of opinion without new facts. As a result, the other grounds regarding the merit of various additions/disallowances raised by the assessee became irrelevant and were not addressed. Consequently, both appeals of the assessee were allowed, and the decision was announced in open court. en-us Thu, 24 Jan 2013 00:00:00 +0530 Mon, 15 Feb 2016 16:51:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178881 The tribunal found that the reopening of the assessment under section 147 was invalid as it was based on a mere change of opinion without new facts. As a result, the other grounds regarding the merit of various additions/disallowances raised by the assessee became irrelevant and were not addressed. Consequently, both appeals of the assessee were allowed, and the decision was announced in open court. Case-Laws Income Tax Thu, 24 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178881