Reopening Tax Assessment u/s 147 Invalid if Based Solely on Return: Constitutes a Change of Opinion.

Reopening of assessment u/s 147 - it is not permissible to adopt different standards while interpreting the words “reason to believe” vis-a-vis Section 143(1) and Section 143(3) - to reopen an assessment based on the return filed by the assessee, will clearly be a case of change of opinion and consequently bad in law. .....

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