Supreme Court upholds High Court decision to quash reopening u/s 147 due to change of opinion, not new evidence.

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....Reopening of the assessment U/S 147 - the High Court has quashed the show cause notice on the ground that the AO has accepted the claim of expenditures during scrutiny assessment u/s 143(3) - therefore the income escaping proceeding has been initiated marely on the basis of change of opinion and cannot sustain - the apex court refused to interfere in the decision of at HC - SC....