Reopening of assessment not permissible where charges on Assessee are not specific: HC

Delhi High Court held In the case of Oracle Systems Corporation vs. ADIT that it is clear that when a regular assessment is completed in terms of Section 143(3), a presumption can be raised that such an order has been passed upon a proper application of mind. Therefore, in our view, what the Assessing Officer is now seeking to do amounts to a clear change of opinion and that is not permissible. Also it is well settled that unless and until the recorded

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