Re-assessment proceedings cannot, be initiated on the ground that the Assessing Officer was legally wrong and had misapplied and wrongly understood the law/legal position

BLB Limited Vs. ACIT  (Delhi HC)

If in the course of original assessment proceedings, the Assessing Officer has considered and examined a particular aspect, the said aspect cannot be made a ground to reopen and initiate reassessment proceedings. The assessing authority cannot have a fresh look and reopen an assessment on the ground of change of opinion.

The facts noticed above, clearly show that in the original assessment

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