Court Rules: No Grounds for Reopening Tax Assessment u/s 147 Due to Mere Change of Opinion.

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....Reopening of assessment u/s 147 - sufficiency or inadequacy of reasons - There is no whisper in the impugned order as regards any failure on the part of petitioner to disclose fully and truly all material facts and as such it is not possible for this Court to infer any such failure on the part of the assessee from the reasons recorded. Petitioner had made adequate disclosures during assessment proceedings which is now sought to be reopened and particularly with reference to ground Nos.1 and 2 on which the respondent authority has proposed to reopen the assessment - change of opinion cannot be the basis for reopening the assessment. - HC....