Reopening beyond 4 years on the basis of Supreme Court’s judgement not justified if assessee not failed to disclose material facts

The judgement of the Supreme Court is an expression of opinion on the interpretation of statute. Merely because a judgement has been rendered, the same cannot be a ground for reopening the assessment u/s 147 as it amounts to a change of opinion. Austin Engineering 312 ITR 70 (Guj) followed).

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