Reopening Tax Assessment Not Justified by Later Opinion Change, Requires "Reason to Believe" u/s 147 of IT Act.

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....Validity of Reopening of assessment u/s 147 - Existence of reason to believe - The issue squarely falls in the realm “change of opinion”. In our view, the only reason that in the succeeding assessment years, the Assessing Officer has come to a different opinion, by itself, may not be a ground to reopen the assessment for an earlier year, wherein a view was conclusively recorded by the concerned Assessing Officer. - HC....