https://www.taxtmi.com/caselaws?id=183328 The court dismissed the Revenue's appeal, affirming that the reopening of assessment beyond the four-year period based on a change of opinion was invalid. The Tribunal emphasized that without new evidence, the assessing officer could not alter the opinion formed during the initial assessment, citing relevant case law to support this position. The court highlighted the stringent conditions for valid reopening beyond four years and underscored that reassessment on a decided issue in favor of the assessee amounted to a mere change of opinion, rendering the reopening invalid. en-us Mon, 30 Jun 2014 00:00:00 +0530 Mon, 06 Jun 2016 11:18:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=183328 The court dismissed the Revenue's appeal, affirming that the reopening of assessment beyond the four-year period based on a change of opinion was invalid. The Tribunal emphasized that without new evidence, the assessing officer could not alter the opinion formed during the initial assessment, citing relevant case law to support this position. The court highlighted the stringent conditions for valid reopening beyond four years and underscored that reassessment on a decided issue in favor of the assessee amounted to a mere change of opinion, rendering the reopening invalid. Case-Laws Income Tax Mon, 30 Jun 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=183328