No change of opinion if AO not examined or applied his mind on a particular issue-HC

HIGH COURT OF DELHI Commissioner of Income-tax Vs. Usha International Ltd. IT Appeal NO. 2026 of 2010 348 ITR 485 (Del.) (FB), September 21, 2012 JUDGMENT Sanjiv Khanna, J. 1. By order dated 23rd April, 2012 in ITA No. 2026/2010, CIT – VI, New Delhi v. Usha International Ltd., the following substantial questions of law have been referred to this Full Bench: “(i)  What is meant by the term “change of opinion? (ii)  Whether assessment proceedings can be validly reopened under Section 147 of the Act, even within four year, if an assessee has furnished full an...