Reopening Assessment u/s 147: Initial Opinion Needed, Change of Opinion Not Allowed Without It.

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....Reopening of assessment u/s 147 - It is trite that there has to be an opinion first only then there can be issue of change of opinion. Moreover it is also settled law that at the time of notice escapement need not be proved to the hilt. We agree with Ld.CIT(A) that AO had valid reason for reopening. - AT....