Court Rejects Reopening Assessment u/s 147 Due to Uncertainty and Change of Opinion by Assessing Officer.

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....Reopening of assessment u/s 147 - As used the expression 'seems' by stating that though the assessee seems to be qualified under clause (a) to Section 43(5), since they had not complied with condition ('d') they are not entitled to any relief. As pointed out earlier reopening, based upon a change of opinion or a review of decision taken by the Assessing officer, is impermissible. - HC....