Court Rules Reopening of Assessment u/s 147 Invalid Due to Mere Change of Opinion by Assessing Officer.

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....Reopening of assessment u/s 147 - review v/s reopening - AO has allowed the Long Term Capital Gains and Short Term Capital Gains claimed by the assessee considering the sell of the Government Securities as investment and not stock-in-trade. Therefore, the reasons recorded by the respondent is mere change of opinion in the facts of the case. - HC....