Change of Opinion on A Particular Matter, Whether Reopening of Assessment Possible?

Advocate Akhilesh Kumar Sah CHANGE OF OPINION BY AO/SUCCESSOR AO ON A PARTICULAR MATTER WHETHER REOPENING OF ASSESSMENT POSSIBLE? There has been constant reopening of assessments by Assessing Authorities on mere change of opinion while law is well settled on the point that an assessment cannot reopened by recourse to section 147/ 148 of the Income tax Act, 1961(for short ‘the Act’) on mere change of opinion of the Assessing Officer(AO). Recently, in Director Of Income Tax International Taxation-II vs. Rolls Royce Industrial Power India Ltd [ITA No. 1058/2011 with ITA Nos. 1061/2011 and 1...