Court Clarifies Limits on Reopening Tax Assessments u/s 147: Distinguishes Between Review and Reassessment Powers.

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....Reopening of assessment u/s 147 - power to review v/s power to reassess - Only material relied upon by the assessing officer, in this case, is the material supplied by the assessees themselves along with their return - A mere change in opinion cannot be a reason to reopen. This decision holds that there is a conceptual difference between power to review and power to reassess and that the assessing officer has no power to simply review - HC....