Change of opinion by AO cannot be base for initiation of re-assessment proceedings

ACIT Vs Dinesh M. Raste (ITAT Pune)

ITAT Pune held that it is an admitted fact that assessee has fully and truly disclosed all the material facts and hence initiation of re-assessment proceedings merely on the change of opinion by AO is impermissible in law.

Facts- The present appeal is preferred by the revenue because CIT(A) has allowed the relief to the assessee by holding that the reopening of the assessment u/s 147/148 of the Income-tax Act, 1961 (hereinafter referred

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