AO cannot act u/s. 147 merely because he happened to change his opinion or to hold an opinion different from that of his predecessor on same set of facts

 ITAT, MUMBAI BENCH `K’, MUMBAI, Audco India Ltd. Vs ITO, A APPEAL NO: ITA No. 6305/M/2007, DECIDED ON April 22, 2010 RELEVANT PARAGRAPH This appeal filed by the assessee is directed against the order of CIT(A)-II, Mumbai, passed on 06.08.2007 for the assessment year 2001- 02. 2. Ground No. 1 is in respect of challenging reopening of assessment u/s 147 of the Act. Grounds No 2 and 3 are on merit related to reduction of profit under section 80IB while computing deduction under section 80HHC of the Act and calculation of deduction under section 80HHC in respect of DEPB re...