AO deemed to have applied his mind if facts are on record

AO deemed to have applied his mind if facts are on record and reopening on change of opinion is not permissible even within 4 years

In CIT Vs Kelvinator of India Ltd. 256 ITR 1 the Full Bench of the Delhi High Court was considering a case of reopening u/s 147 within 4 years from the end of the assessment year. The Court held that when a regular order of assessment is passed in terms of section 143 (3) of the Act, a presumption can be raised that such an order has been passed on application of mind. I

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