https://www.taxtmi.com/caselaws?id=35223 The court held that the Assessing Officer had the jurisdiction to reopen assessments under Section 147. It was determined that the reassessment orders were invalid as they were based solely on a change of opinion without any other grounds. The court clarified that the communication under Section 143(1) did not amount to an assessment order, and therefore, the question of change of opinion did not arise. Additionally, it was emphasized that the acknowledgment of the return under Section 143(1) did not constitute an assessment. The Tribunal's decision to set aside the reassessment orders was overturned, and the matter was remitted for fresh consideration without consideration of change of opinion. The appeals were allowed in favor of the revenue. en-us Mon, 11 Jan 2010 00:00:00 +0530 Mon, 31 Dec 2012 10:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35223 The court held that the Assessing Officer had the jurisdiction to reopen assessments under Section 147. It was determined that the reassessment orders were invalid as they were based solely on a change of opinion without any other grounds. The court clarified that the communication under Section 143(1) did not amount to an assessment order, and therefore, the question of change of opinion did not arise. Additionally, it was emphasized that the acknowledgment of the return under Section 143(1) did not constitute an assessment. The Tribunal's decision to set aside the reassessment orders was overturned, and the matter was remitted for fresh consideration without consideration of change of opinion. The appeals were allowed in favor of the revenue. Case-Laws Income Tax Mon, 11 Jan 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35223