High Court: Reopening Tax Assessments Needs Valid Reason, Not Just Different Income Disclosure by Another Director.

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....Reopening of the assessment u/s 147 - Reason to believe - change of opinion - merely because another director of the same company had disclosed the income received differently, cannot be a ground for reopening and the same is evidently a change of opinion not only based on conjectures and surmises but also a case of blindly relying on information and borrowed satisfaction which is not permitted for reopening - HC....