Reopening of assessment not permissible where charges on Assessee are not specific: HC

Brief of the Case Delhi High Court held In the case of Oracle Systems Corporation vs. ADIT that it is clear that when a regular assessment is completed in terms of Section 143(3), a presumption can be raised that such an order has been passed upon a proper application of mind. Therefore, in our view, what the Assessing Officer is now seeking to do amounts to a clear change of opinion and that is not permissible. Also it is well settled that unless and until the recorded reasons specifically indicated as to which material facts were not disclosed by the petitioner in the course of the original ...