https://www.taxtmi.com/highlights?id=68343 Reopening of assessment u/s 147 - Reasons to belive - change of opinion - there was no new material which had come to the notice of the Assessing Officer and the entire reference in the reasons recorded is only to the material on record. - issue with regard to depreciation had been gone into by the said AO without making any disallowance as regards the claim of the depreciation - the reassessment proceedings were nothing but a case of ‘change of opinion’, which does not comply with the jurisdictional foundation under section 147 - HC en-us Sat, 18 Feb 2023 14:06:24 +0530 Sat, 18 Feb 2023 14:06:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=68343 Reopening of assessment u/s 147 - Reasons to belive - change of opinion - there was no new material which had come to the notice of the Assessing Officer and the entire reference in the reasons recorded is only to the material on record. - issue with regard to depreciation had been gone into by the said AO without making any disallowance as regards the claim of the depreciation - the reassessment proceedings were nothing but a case of ‘change of opinion’, which does not comply with the jurisdictional foundation under section 147 - HC Highlights Income Tax Sat, 18 Feb 2023 14:06:24 +0530 https://www.taxtmi.com/highlights?id=68343