Reopening Assessments for Under-Reported Capital Gains Valid u/s 147 if Relevant Facts Overlooked; Not a 'Change of Opinion'.

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....Validity of reopening of assessment u/s 147 - under-reporting of capital gains - where the relevant facts have been overlooked and has not taken cognizance of, resulting in escapement of chargeable income, such omission would not constitute ‘change of opinion’. In the absence of any other contention, we do not see any merit in the plea of assessee towards wrongful usurpation of jurisdiction u/s 147 - AT....