https://www.taxtmi.com/caselaws?id=405384 The appeal challenged the reopening of assessment under section 147 of the Income Tax Act, alleging it to be a change of opinion. The Tribunal held that the AO's failure to consider the deemed sale consideration did not constitute a 'change of opinion' as the issue was not examined previously. The Tribunal emphasized the importance of considering all relevant facts in the assessment process and dismissed the appeal, stating that the omission of significant facts led to an escapement of chargeable income. en-us Fri, 19 Feb 2021 00:00:00 +0530 Fri, 19 Mar 2021 09:19:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=405384 The appeal challenged the reopening of assessment under section 147 of the Income Tax Act, alleging it to be a change of opinion. The Tribunal held that the AO's failure to consider the deemed sale consideration did not constitute a 'change of opinion' as the issue was not examined previously. The Tribunal emphasized the importance of considering all relevant facts in the assessment process and dismissed the appeal, stating that the omission of significant facts led to an escapement of chargeable income. Case-Laws Income Tax Fri, 19 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=405384