S. 147/148 AO cannot review his decision & reopen on a change of opinion

BPTP Limited Vs PCIT (Delhi High Court) Section 147 of the IT Act does not allow the reassessment of an income merely because of the fact that the assessing officer has a change of opinion with regard to the interpretation of law differently on the facts that were well within his knowledge even at the time of assessment. Doing so would have the effect of giving the assessing officer the power of review and Section 147 confers the power to reassess and not the power to review. Merely using the expression “failure on the part of the assessee to disclose fully and truly all material facts” is...