Court Validates Reassessment u/s 147: No Change of Opinion in Donations Inquiry u/s 35(1)(ii.

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....Reopening of assessment u/s 147 - Change of opinion - the threshold bar for initiation of the reassessment proceedings is satisfied. This Court must conclude, at this stage, that the AO's subjective prima facie opinion, though is based on the records made available during the assessment proceedings, is because of further enquiry, into the affairs of organization to whom donations were made u/s 35(1)(ii), and this is not a case of 'change of opinion'. - HC....