High Court Quashes Reopening of Tax Assessment; Section 147 Bars Reassessment on Changed Opinion Without New Facts.

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....Reopening of assessment u/s 147 - It is clear that the primary facts necessary for assessment were also disclosed. It is settled law that the Assessing Officer is not entitled for change of opinion to commence proceedings for reassessment. It is also settled law that when on consideration of material on record, one view is conclusively taken by the Assessing Officer, it would not be open to reopen the assessment based on the very same material with a view to take another view. Notice is hereby quashed - HC....