High Court rules reopening assessments u/s 147 invalid if facts were fully disclosed; change of opinion insufficient.

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....Reopening of assessment u/s 147 - net loss of cancellation of forward contract - When the primary facts necessary for assessment are fully and truly disclosed, the AO is not entitled on change of opinion to commence proceedings for reassessment. Even if the AO, who passed the assessment order, may have raised too many legal inferences from the facts disclosed, on that account the AO, who has decided to reopen assessment, is not competent to reopen assessment proceedings. - HC....