https://www.taxtmi.com/highlights?id=60840 Reopening of assessment u/s 147 - Change of opinion - We are of a strong conviction that in the garb of reopening the case of the assessee he had on the basis of the same set of facts as were available on record at the time of framing of the original assessment, tried to substitute his view as against that of his predecessor. In fact, we are unable to comprehend as to what new “material” or “information” had came to the notice of the A.O after the framing of the original assessment, which would have justified the reopening of its case. - AT en-us Wed, 08 Dec 2021 08:57:26 +0530 Wed, 08 Dec 2021 08:57:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=60840 Reopening of assessment u/s 147 - Change of opinion - We are of a strong conviction that in the garb of reopening the case of the assessee he had on the basis of the same set of facts as were available on record at the time of framing of the original assessment, tried to substitute his view as against that of his predecessor. In fact, we are unable to comprehend as to what new “material” or “information” had came to the notice of the A.O after the framing of the original assessment, which would have justified the reopening of its case. - AT Highlights Income Tax Wed, 08 Dec 2021 08:57:26 +0530 https://www.taxtmi.com/highlights?id=60840