Reopening Tax Assessments Requires Valid Reason, Not Just Opinion Change: Section 147 Interpretation Clarified in Recent Case.

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....Reopening of assessment u/s 147 - change of opinion - "Reason to believe" based on mere change of opinion - the decision in the case of Rinku Chakraborthy does not lay down correct position law to the extent to which it follows what is held in clause (2) of paragraph 13 of the decision of the Apex Court in the case of Kalyanji Mavji and Company (supra). - HC....