Reassessment u/s 147 Not Allowed for Mere Opinion Change if Facts Fully Disclosed and Assessed.

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....Reopening of assessment u/s 147 - change of opinion - when the primary facts necessary for assessment are fully and truly disclosed, the Assessing Officer is not entitled to a change of opinion for commencing proceedings for reassessment. It is also held that when on consideration of the material on record, one view is conclusively taken by the Assessing Officer, it would not be open for the Assessing Officer to reopen assessment based on the very same material and to take another view. - HC....