When there is detailed scrutiny with regard to an issue, no re-opening for mere change of opinion

HIGH COURT OF GUJARAT Gujarat Tea Processors & Packers Ltd. Versus Deputy Commissioner of Income-tax SPECIAL CIVIL APPLICATION NO. 12673 OF 2011 AUGUST 31, 2012 JUDGMENT Ms. Sonia Gokani, J. – Petitioner is a public limited company dealing in manufacture and sale of Tea. The petitioner submitted return for the AY 2006-07 on 26th December 2006. A revised return was filed on 26th October 2007 alongwith computation of the total income which was picked up for scrutiny assessment by the respondent. A letter was addressed on 18th December 2008 calling for certain informati...