Reopening of assessment u/s 147 - Change of opinion - As has always been observed, notice under Section...

Reopening of assessment u/s 147 - Change of opinion - As has always been observed, notice under Section 147 is not to be casually invoked to suit the convenience of the Department or to correct any alleged errors which would have been committed by the Assessing Officer. In the instant case, we find that, not only the ingredients required to be fulfilled in the first proviso to Section 147 have not been fulfilled, there is no allegation made against the assessee for not having made full or true d..... .....

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