https://www.taxtmi.com/highlights?id=59188 Reopening of assessment u/s 147 - It is trite that there has to be an opinion first only then there can be issue of change of opinion. Moreover it is also settled law that at the time of notice escapement need not be proved to the hilt. We agree with Ld.CIT(A) that AO had valid reason for reopening. - AT en-us Fri, 13 Aug 2021 08:51:42 +0530 Fri, 13 Aug 2021 08:51:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=59188 Reopening of assessment u/s 147 - It is trite that there has to be an opinion first only then there can be issue of change of opinion. Moreover it is also settled law that at the time of notice escapement need not be proved to the hilt. We agree with Ld.CIT(A) that AO had valid reason for reopening. - AT Highlights Income Tax Fri, 13 Aug 2021 08:51:42 +0530 https://www.taxtmi.com/highlights?id=59188