High Court Rules Change of Opinion Insufficient for Reassessment u/s 147 of Income Tax Act.

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....Reopening of assessment u/s 147 - change of opinion to commence proceedings for reassessment - An Assessing Officer is not permitted to make a roving inquiry. We are, therefore, not satisfied that the reasons given by the Assessing Officer make out any case of failure on the part of petitioner to fully and truly disclosed material facts. - HC....