Reassessment Invalid as Mere Change of Opinion Is Not Reason to Believe: Karnataka HC

Dell India Private Limited Vs JCIT Large Tax Payers Unit (LTU) (Karnataka High Court) The Karnataka High Court Full Bench examined three legal questions relating to reassessment proceedings under Section 147 of the Income Tax Act, 1961, particularly whether reassessment can be initiated merely on a “change of opinion” by the Assessing Officer. The case arose from reassessment proceedings initiated against an assessee engaged in manufacturing and selling computer hardware and related products. The assessee followed a “deferred revenue” accounting system for extended warranty services, u...