https://www.taxtmi.com/highlights?id=62115 Reopening of assessment u/s 147 - True and full disclosure of all material facts - It is true that in the assessment order self-disallowances have not been discussed but at the same time it has been a subject of consideration during the assessment proceedings since the Assessing Officer has started from the business income as returned by petitioner, which included self-disallowances debited to the P&L Account. - it is a clear case of change of opinion to take a different view relying on the same set of documents. Change in opinion cannot construe “reason to believe”. - HC en-us Thu, 24 Feb 2022 07:14:02 +0530 Thu, 24 Feb 2022 07:14:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=62115 Reopening of assessment u/s 147 - True and full disclosure of all material facts - It is true that in the assessment order self-disallowances have not been discussed but at the same time it has been a subject of consideration during the assessment proceedings since the Assessing Officer has started from the business income as returned by petitioner, which included self-disallowances debited to the P&L Account. - it is a clear case of change of opinion to take a different view relying on the same set of documents. Change in opinion cannot construe “reason to believe”. - HC Highlights Income Tax Thu, 24 Feb 2022 07:14:02 +0530 https://www.taxtmi.com/highlights?id=62115