Reopening based on change of opinion is not permissible under law

Advocate Akhilesh Kumar Sah Motorola Inc, USA Vs DDIT (ITAT Delhi) Motorola Inc, USA appeal before Delhi ITAT: When no intangible material came to the notice of the AO to form the opinion that the income of the assessee company has escaped assessment and all the facts and figures have been brought on record by the assessee company during assessment proceedings and same had been explained: The reassessment proceedings were not sustainable, having been made after a period of 4 years from the relevant assessment years In Motorola Inc, USA vs. DDIT [ITA No. 5679 /Del/2010 (A.Y.: 2002-03) & I...