No reassessment for mere change of opinion by the AO

Jagdish U. Thackersey Vs DCIT (ITAT Mumbai)

It is well settled that mere fresh application of mind to the same set of facts or mere change of opinion does not confer jurisdiction even under the post-1989 section 147. The consistent view is that even after amendment of section 147 (w.e.f. 01.04.1989) mere change of opinion does not confer jurisdi

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