Court Invalidates Assessment Reopening u/s 147 Due to Change of Opinion; Favors Assessee's Challenge.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reopening of assessment u/s 147 - 'reason to believe' OR 'reason to suspect' - AO reopened the assessment based on change of opinion, which is not acceptable as per the decisions quoted supra. Therefore, we quash the reopening of assessment made by the AO and the grounds raised by the assessee on this issue are allowed. - AT....