Reassessment u/ss 147 and 148 Upheld: No "Change of Opinion" as Initial Return Accepted Without Review.

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....Reopening of assessment u/s 147 r.w.s. 148 - since the assessee's return was accepted under section 143(1) of the Income-tax Act, there was no question of "change of opinion" inasmuch as while accepting the return under the aforesaid provision no opinion was formed - reassessment proceedings sustained - SC....