Reopening of completed assessment based on change of opinion not permissible

CavinKare Pvt. Ltd. Vs DCIT (Madras High Court) It is the case of the petitioner that reopening of the assessment was based on the change of opinion for the year 2011-2012, and there was no ground for reopening of the assessment under Section 148 of the Income Tax Act for the purpose of Section 147 of the Income Tax Act, as the petitioner had not suppressed any information required for completing the assessment. Reopening of the completed assessment based on change of opinion has been frowned upon by the Apex Court by its several decisions. The decision cited by the petitioner are squarely app...