Return of income processed u/s 143(1) cannot be reassessed u/s 147 on mere change of opinion of AO

In this case, the reasons provided under Section 148 are that “by reason of omission or failure on the part of the assessee to disclose truly and fully all material facts necessary for assessment and by wrong treatment of income”, certain income has escaped assessment. However, no details are provided as regards what such information is, which engaged the attention of the AO and was not disclosed by the assessee while filing returns. The reasons must indicate specifically what such objective material facts are, on the basis of which a reopening is initiated under Section 148. There is a va...