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 t

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