Reopening Tax Assessment Invalid Without New Evidence; Change of Opinion Not Permissible, Court Rules in Favor of Assessee.

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....The High Court held that reopening of assessment u/s 147 was not valid where the Assessing Officer had previously examined the claim for deduction of foreign exchange loss during regular scrutiny assessment and had allowed the deduction after considering the assessee's explanation. The Court ruled that in the absence of any new tangible material, the Assessing Officer could not assume jurisdiction to reopen the assessment merely on a change of opinion. If the Assessing Officer had made any legal error in the original assessment, the succeeding officer cannot correct such error through reopening. The reasons recorded clearly reflect an attempt to correct the earlier opinion, which cannot be the basis for reopening an assessment framed after scrutiny. The decision was in favor of the assessee.....