https://www.taxtmi.com/caselaws?id=426030 The High Court of Calcutta analyzed the validity of reopening the assessment under Section 147 of the Income Tax Act, 1961, and the issue of a change of opinion by the Assessing Officer. The Court found that the reassessment proceedings were indeed a case of change of opinion, and the Tribunal's decision to grant relief to the assessee was justified. Legal precedents were cited to support the conclusion that reassessment should not be based on a mere change of opinion but on specific pre-conditions. The Court dismissed the revenue's appeal and upheld the Tribunal's order, emphasizing that a fresh decision based on the same material would amount to a review of the original assessment. en-us Tue, 02 Aug 2022 00:00:00 +0530 Sat, 06 Aug 2022 17:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=426030 The High Court of Calcutta analyzed the validity of reopening the assessment under Section 147 of the Income Tax Act, 1961, and the issue of a change of opinion by the Assessing Officer. The Court found that the reassessment proceedings were indeed a case of change of opinion, and the Tribunal's decision to grant relief to the assessee was justified. Legal precedents were cited to support the conclusion that reassessment should not be based on a mere change of opinion but on specific pre-conditions. The Court dismissed the revenue's appeal and upheld the Tribunal's order, emphasizing that a fresh decision based on the same material would amount to a review of the original assessment. Case-Laws Income Tax Tue, 02 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=426030