Assessment Reopening Can't Be Used to Review Orders: Section 147, Even if Initiated Within Four Years, Change of Opinion.

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....Reopening of assessment u/s 147 - There is no power granted to the AO under the statute to review the order in the garb of initiating the proceedings under section 147 of the Act. Accordingly we hold that, there will not be any difference whether the proceedings were initiated within 4 years or beyond the 4 years as far as change of opinion is concerned. - AT....