Reopening cannot be proposed on the basis of change of opinion

Lokhandwala Construction Industries Private Limited Vs DCIT (Bombay High Court)

Once a query is raised during assessment proceedings and assessee has replied to it, it follows that the query raised was a subject matter of consideration of the Assessing Officer while completing the assessment. It is not necessary that an assessment order should contain reference and/or discussion to disclose its satisfaction in respect of the query raised. In this case, during the original assessment proceedings, a notice dated 19^{thPlease become a Premium member. If you are already a Premium member, login here to access the full content.}