Mere change of opinion not sustainable in the eyes of law in respect of reopening of the case: Hitachi Home case

Advocate Akhilesh Kumar Sah Hitachi Home & Life Solutions (I) Ltd. Vs ACIT (ITAT Ahmedabad) Assessing authority ought not to reopen regular assessment on the ground that it had not applied correct provision of law in finalizing scrutiny assessment in absence of tangible material as the same would amount to mere change of opinion in such circumstances. In Hitachi Home & Life Solutions (I) Ltd. vs. ACIT [ITA Nos. 3045/Ahd/2013 & 104/Ahd/2014, decided on 17.01.2017], briefly, the assessee being a company manufacturing/trading in air conditioners filed return of income on 20.12.2006 s...