Re-opening of assessment not permissible on same set of materials considered in original assessment

Delhi High Court held In the case of Turner Broadcasting Systems Asia Pacific INC. vs. DDIT that the assessing officer has merely intended to revisit the concluded assessments and it is a clear case of change of opinion, which is not permissible in law. It is clear that no fresh information or material has been referred to in the reasons recorded for reopen the assessment. The material that is referred to is the very same material that was already before the Assessing

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