Reassessment proceedings on basis of change of opinion was invalid

City Union Bank Limited Vs ACIT (Madras High Court) Conclusion: Reassessment could not be reopened on basis of change of opinion in case the matter of dis allowance had already been considered during the original assessment proceedings because the authority could not take advantage of their own wrong if they failed to perform their statutory duty. Held: Assessee-bank received notice under section 148 proposing to initiate proceedings under section 147. Assessee contended that the notice was issued beyond four years from the end of the assessment year and there had been no failure on the part o...