Change of opinion impermissible under the grab of reopening u/s 147

Ultra Tech Cement Ltd Vs CIT (ITAT Mumbai) ITAT Mumbai held that change of opinion is not permissible under the garb of reopening of assessment under section 147/148 of the Income Tax Act. Facts- The assessee being a public limited company is into manufacturing and trading and sale of cement filed its return of income for the year under consideration declaring total income at Rs.2284,05,32,680/-, there after filed revised return at total income of Rs.2283,30,74,150/-. On the basis of search and seizure operation carried out u/s. 132 of the Income Tax Act at the premises of Aditya Birla Managem...