Concept of “change of opinion” stands obliterated WEF 01.04.1989?

CIT Vs Kelvinator of India Limited (Supreme Court of India) Explore the Supreme Court’s ruling on change of opinion in tax assessments & Section 147 amendments post Direct Tax Laws (Amendment) Act, 1987 Under the Direct Tax Laws (Amendment) Act, 1987, Parliament not only deleted the words ‘reason to believe’ but also inserted the word ‘opinion’ in Section 147 of the Act. However, on receipt of representations from the Companies against omission of the words ‘reason to believe’, Parliament re-introduced the said expression and deleted the word ̵...