Reassessment on the basis of change of opinion, bad-in-law

Uttarakhand Purv Sainik Kalyan Nigam Ltd. Vs ITO (ITAT Dehradun) Reassessment on the basis of change of opinion, bad-in-law, more-so, when the case was re-opened after the expiry of four year and there was no non-disclosure which could be attributable to the assessee A) Re-opening of assessment on the same issue which was dealt during scrutiny proceedings is impermissible on account of change of opinion. A1) The original order does not need to be detailed, even if it is silent/cryptic on the issue but there are other aspects such as the notices, replies and discussion about the same in the ord...