Reassessment on the basis of change of opinion is forbidden by law

Brief about the case The Assessing Officer had issued notice u/s 148 of IT act to reopen the assessment giving reasons to believe that assessee’s claim for set off of brought forward unabsorbed depreciation against long term capital gain was not allowable as it was being set off after a lapse of 8 years. According to the assessee, it had disclosed all material facts fully and truly, in the course of assessment proceedings including all long term capital gains, trial run expenses and bad debts during the course of original assessment proceedings. The assessee further asserted that the Ass...