AO not entitled to commence proceedings for reassessment based on change of opinion

DCW Limited Vs ACIT (Bombay High Court) Bombay High Court held that AO is not entitled to commence proceedings for reassessment under section 147 of the Income Tax Act based on change of opinion as material facts are fully and truly disclosed. Facts- Petitioner had filed its return of income for A.Y. 2014-15 on 29th November 2014. It was processed and intimation u/s. 143(1) of the Income Tax Act, 1961 was issued. Subsequently, Petitioner’s case was selected for scrutiny assessment. Petitioner was called upon to file several details pertaining to Petitioner’s claim for deductions u/s. 32AC...