https://www.taxtmi.com/caselaws?id=9473 HC dismissed the writ petition, upholding reopening under s.147. The court held that reassessment was permissible even where reasons arose from records used in the original assessment, since the bar on reopening as a mere "change of opinion" applies only if the AO had previously applied his mind and reached a conscious decision on the same issue. Mere production of books or documents does not amount to full and true disclosure under Explanation 1. Because the original order did not address the aspect relied on for reopening, the reassessment suffered no jurisdictional defect. en-us Tue, 17 Jan 2006 00:00:00 +0530 Fri, 19 Sep 2025 17:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9473 HC dismissed the writ petition, upholding reopening under s.147. The court held that reassessment was permissible even where reasons arose from records used in the original assessment, since the bar on reopening as a mere "change of opinion" applies only if the AO had previously applied his mind and reached a conscious decision on the same issue. Mere production of books or documents does not amount to full and true disclosure under Explanation 1. Because the original order did not address the aspect relied on for reopening, the reassessment suffered no jurisdictional defect. Case-Laws Income Tax Tue, 17 Jan 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9473