Court Rules Change of Opinion Insufficient for Reopening Tax Assessment; No Income Found to Have Escaped Assessment.

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....Reopening of assessment - concept of change of opinion - The court agreed with the petitioner's argument, stating that the reopening of the assessment was indeed based on a change of opinion by the Assessing Officer, as the issue had already been considered and no additions were made during the original assessment proceedings. The court held that such a change of opinion did not justify the assumption that income chargeable to tax had escaped assessment.....