Assessment Reopening Needs Valid Reasons, Not Opinion Change; Clerical Errors Addressed u/s 154, Not Section 147.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reopening of assessment u/s 147 - eligibility of reasons to believe - change of opinion - nowhere AO has been able to make out a case that there was any omission or failure on the part of the petitioner to disclose fully and truly the necessary material facts - if at all there was any clerical/arithmetical mistake apparent from record then recourse was available to the assessing officer by way of rectification under Section 154 of the Income Tax Act, 1961 and that cannot be a ground of reopening of an assessment for correcting a mistake in calculation of an amount of disallowance causing alleged escapement of income. - HC....