AO not entitled on change of opinion to commence reassessment proceedings

Macrotech Developers Limited Vs ACIT (Bombay High Court) The question is whether there was a failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment of Assessment Year 2012-13. It is not the case that there is failure on the part of the assessee to make a return under Section 139 of the Act. The case of the assessee was selected for scrutiny for Assessment Year 2012-13 and it is after complete examination of the original computation of income, revised computation of income and audit, the Assessing Officer has allowed the claim of the asse...