Reopening of Assessment not allowed to Form Change of Opinion

PCIT Vs Safe Corrugated Containers Pvt. Ltd. (Madras High Court) The issue under consideration is whether the reassessment proceeding u/s 147 initiated to form change of opinion which clearly amount to reviewing the original order of assessment is justified in law? High Court states that, on perusal of Section 147, it is clear that if the Assessing Officer has reason to believe that any income chargeable has escaped assessment for any assessment year, the reassessment can be made. But, in the present case, no income was escaped from the assessment. The loss on sale of shares was disclosed by t...