https://www.taxtmi.com/highlights?id=59236 Reopening of assessment u/s 147 - Change of opinion - As has always been observed, notice under Section 147 is not to be casually invoked to suit the convenience of the Department or to correct any alleged errors which would have been committed by the Assessing Officer. In the instant case, we find that, not only the ingredients required to be fulfilled in the first proviso to Section 147 have not been fulfilled, there is no allegation made against the assessee for not having made full or true disclosure of all material particulars and the reopening of the assessment would also be barred in terms of the third proviso to Section 147 - HC en-us Tue, 17 Aug 2021 09:03:43 +0530 Tue, 17 Aug 2021 09:03:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=59236 Reopening of assessment u/s 147 - Change of opinion - As has always been observed, notice under Section 147 is not to be casually invoked to suit the convenience of the Department or to correct any alleged errors which would have been committed by the Assessing Officer. In the instant case, we find that, not only the ingredients required to be fulfilled in the first proviso to Section 147 have not been fulfilled, there is no allegation made against the assessee for not having made full or true disclosure of all material particulars and the reopening of the assessment would also be barred in terms of the third proviso to Section 147 - HC Highlights Income Tax Tue, 17 Aug 2021 09:03:43 +0530 https://www.taxtmi.com/highlights?id=59236