View contrary to the earlier view taken by the Assessing Officer while completing the original assessment amounts to change of opinion

RELEVANT PARAGRAPH 12. Under the provisions of Section 147 of the I.T. Act, the Assessing Officer has the power to reassess the income for any Assessment Year where he has a reason lo believe that any income chargeable to tax had escaped assessment for any Assessment Year. The power is also given to Assessing Officer to recompute the loss or the depreciation allowance or any other allowance for the Assessment Year concerned the said power is to be exercised subject to the provisions of Section 148 to 153 of the I. T Act. However, the proviso to Section 147 of the I.T. Act curtail the power of ...