https://www.taxtmi.com/highlights?id=61990 Reopening of assessment u/s 147 - Change of opinion - TP adjustment addition - Courts have repeatedly held that once a query is raised and that has been explained by the assessee, even if there is no discussion on that aspect in the assessment order still the Assessing Officer is deemed to have consider these points and applied his mind. - All these only indicate one thing that re-opening is proposed on the basis of change of opinion. - HC en-us Thu, 17 Feb 2022 15:00:07 +0530 Thu, 17 Feb 2022 15:00:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=61990 Reopening of assessment u/s 147 - Change of opinion - TP adjustment addition - Courts have repeatedly held that once a query is raised and that has been explained by the assessee, even if there is no discussion on that aspect in the assessment order still the Assessing Officer is deemed to have consider these points and applied his mind. - All these only indicate one thing that re-opening is proposed on the basis of change of opinion. - HC Highlights Income Tax Thu, 17 Feb 2022 15:00:07 +0530 https://www.taxtmi.com/highlights?id=61990