https://www.taxtmi.com/caselaws?id=16457 HC held that the Assessing Officer validly invoked section 147 upon discovering that a capital asset had been converted into stock-in-trade, giving rise to capital gains that escaped assessment for AY 1991-92. The court found there was evidence of primary facts to form a reason to believe and that the AO's exercise of jurisdiction was within statutory scope; sufficiency of that belief is for appeal against the assessment, not for writ of prohibition. Errors in the original assessment that justify correction are not mere change of opinion. Petitions challenging reassessment were dismissed. en-us Thu, 19 Feb 1998 00:00:00 +0530 Fri, 10 Oct 2025 17:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16457 HC held that the Assessing Officer validly invoked section 147 upon discovering that a capital asset had been converted into stock-in-trade, giving rise to capital gains that escaped assessment for AY 1991-92. The court found there was evidence of primary facts to form a reason to believe and that the AO's exercise of jurisdiction was within statutory scope; sufficiency of that belief is for appeal against the assessment, not for writ of prohibition. Errors in the original assessment that justify correction are not mere change of opinion. Petitions challenging reassessment were dismissed. Case-Laws Income Tax Thu, 19 Feb 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16457