Re-opening of assessment based on mistake of opinion is bad in law

ACIT Vs M/s. Sattva Developers Pvt. Ltd. (ITAT Kolkata) From the entry made on 06-09-2011, it would be found that the Authorised Representative filed all the details excepting the explanation regarding treatment of compensation, and for this purpose the hearing was adjourned to 13-09-2011. The next entry on 19-09-2011 inter alia reads that the Authorised Representative appeared and submitted the details asked for. In view of above, I am of the view that it is a case of change of opinion only and nothing else and I further held that a case cannot be re-open on the basis of change of opinion. Th...