Reassessment u/s 147 invalid: AO can't reopen case based on changed opinion or superior's direction.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reassessment u/s 147 - within four years from the end of the relevant AY - AO resisted the audit objection and defended the completion of assessment - AO merely changing his opinion or having a second thought on the basis of materials on record and that too reluctantly and reeling under the dictation from the superior officer - reopening not valid....