Mere Change of Opinion Cannot be Basis for Re-Opening of Assessment

DCIT Vs K.V. Mohana Rao and Co. Pvt. Ltd. (ITAT Visakhapatnam) The issue under consideration is whether the re-opening of assessment u/s 147 is justified if the details on the basis of which case is re-opened was already available at the time of original assessment? ITAT states that the concept of “change of opinion” on the part of the Assessing Officer to reopen the assessment does not stand obliterated by substitution of Section 147 of the Income Tax Act, 1961 by Direct Tax Laws (Amendment) Act, 1987 & 1989 after the amendment the Assessing Officer has a reason to believe tha...