Re-assessment of income u/s 147 merely based on change of opinion invalid

Murlimanohar Ramkishan Mundhra Vs ITO (ITAT Surat) ITAT Surat held that section 147 doesn’t allow the re-assessment of an income merely because of the fact that AO has change of opinion with regard to the interpretation of law differently on the facts that were well within his knowledge even at the time of assessment. Facts- The assessee is an individual and engaged in trading and manufacturing of textile fabrics, filed his return of income on 11.10.2013 declaring income of Rs.4,68,140/- for A.Y. 2013-14. The assessment was completed u/s. 143(3) on 23.03.2016 at Rs.5,17,750/-. Subsequently, ...