Reassessment on change of opinion invalid; deduction u/s 54B stands.

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....The High Court held that the reopening of assessment was invalid. Despite the amendment made in 1998 to Section 147 of the Act, reassessment proceedings cannot be initiated based on a change of opinion. The Assessing Officer (AO) had previously considered the issue of deduction u/s 54B and formed an opinion, albeit without recording reasons. The explanation provided by the petitioner was accepted, and the deduction u/s 54B was allowed. Consequently, the notice issued u/s 148 for the assessment year 2009-2010 and the order rejecting the objections were quashed by the High Court.....