Court Rules Against Reopening Assessment u/s 147 Based on Change of Opinion, Upholding Section 80I Deduction Validity.

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....Reopening of assessment u/s 147 - Notice after the expiry of period of four years - Admissibility of deduction u/s 80I - The issue was already considered by the AO - In our view, the exercise to reopen a validly framed assessment is merely on the basis of change of opinion by succeeding Assessing Officer and such a mere change of opinion cannot justify the exercise of jurisdiction under Section 148. - HC....