Reopening of Assessment for Mere Change of Opinion is unjustified

PCIT Vs Shri. K. R. Jayaram (Madras High Court) The issue under consideration is Whether the Tribunal was justified in holding that the reopening of assessment was a result of mere change of opinion, even when there is no opinion formed or expressed by the Assessing Officer on this issue in the original assessment? High Court states that, in light of the decision of the Hon’ble Supreme Court in the case of Calcutta Discount Co., Ltd., vs. ITO [1961] 41 ITR 191 (SC), wherein the Hon’ble Supreme Court held that the duty of the assessee is to make full and true disclosure of all prima...