https://www.taxtmi.com/caselaws?id=396733 The Court found that the reopening of the assessment under Section 147 of the Income Tax Act was invalid as it constituted a change of opinion. The Court emphasized that the Assessing Officer must have "reasons to believe" that income escaped assessment, which cannot be solely based on a change of opinion. The Court referenced judicial precedents, including the Kelvinator decision, which established that a mere change of opinion does not authorize reopening under Section 147. The appeal by the Revenue was dismissed, confirming that the reopening was not valid, and the decision of the Tribunal and CIT(A) was upheld. en-us Mon, 13 Jul 2020 00:00:00 +0530 Fri, 17 Jul 2020 11:45:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=396733 The Court found that the reopening of the assessment under Section 147 of the Income Tax Act was invalid as it constituted a change of opinion. The Court emphasized that the Assessing Officer must have "reasons to believe" that income escaped assessment, which cannot be solely based on a change of opinion. The Court referenced judicial precedents, including the Kelvinator decision, which established that a mere change of opinion does not authorize reopening under Section 147. The appeal by the Revenue was dismissed, confirming that the reopening was not valid, and the decision of the Tribunal and CIT(A) was upheld. Case-Laws Income Tax Mon, 13 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=396733