https://www.taxtmi.com/caselaws?id=759497 Gujarat HC held that reopening of assessment under section 147 was invalid as it constituted mere change of opinion. The assessee had fully disclosed service tax liability in balance sheet and satisfied all queries during original assessment proceedings under section 143(3). The AO attempted reassessment based on re-verification of existing records without any new tangible material or information. The court ruled that assumption of jurisdiction under section 147 is impermissible when based solely on change of opinion rather than discovery of new facts. en-us Mon, 12 Aug 2024 00:00:00 +0530 Thu, 03 Oct 2024 07:50:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759497 Gujarat HC held that reopening of assessment under section 147 was invalid as it constituted mere change of opinion. The assessee had fully disclosed service tax liability in balance sheet and satisfied all queries during original assessment proceedings under section 143(3). The AO attempted reassessment based on re-verification of existing records without any new tangible material or information. The court ruled that assumption of jurisdiction under section 147 is impermissible when based solely on change of opinion rather than discovery of new facts. Case-Laws Income Tax Mon, 12 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759497