https://www.taxtmi.com/highlights?id=72802 Reopening of assessment u/s 147 - reason to believe - Assessing Officer has no power to review; he has the power to re-assess. But re-assessment has to be based on fulfillment of certain pre-condition and if the concept of “change of opinion” is removed, as contended on behalf of the Department, then, in the garb of re-opening the assessment, review would take place. One must treat the concept of “change of opinion” as an in-built test to check abuse of power by the Assessing Officer. - HC en-us Mon, 30 Oct 2023 08:50:49 +0530 Mon, 30 Oct 2023 15:30:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=72802 Reopening of assessment u/s 147 - reason to believe - Assessing Officer has no power to review; he has the power to re-assess. But re-assessment has to be based on fulfillment of certain pre-condition and if the concept of “change of opinion” is removed, as contended on behalf of the Department, then, in the garb of re-opening the assessment, review would take place. One must treat the concept of “change of opinion” as an in-built test to check abuse of power by the Assessing Officer. - HC Highlights Income Tax Mon, 30 Oct 2023 08:50:49 +0530 https://www.taxtmi.com/highlights?id=72802