Reopening Tax Assessment Requires New Evidence, Not Mere Change in Opinion Under Section 147

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....HC held that the Assessing Officer could not reopen the assessment merely on a change of opinion. The court found that the petitioner had already disclosed all relevant facts during the original assessment, including TDS details and deductions under section 80IC. The reopening of assessment was deemed improper as it did not reveal any new information constituting income escapement. The court emphasized that reassessment is not equivalent to reviewing the original assessment order. The procedural provisions and amendments to sections 147 and 148 did not alter the fundamental principle against reopening assessments based solely on a different interpretation of existing information. Judgment was decided in favor of the assessee.....