The contingent or non-existing liabilities which were claimed and allowed under section 143(1)(a) would amount to income escaping assessment

RELEVANT PARAGRAPH 7. We have carefully considered the relevant facts, arguments advanced and the case laws cited. It is not in dispute that the assessments sought to be reopened were earlier completed only by accepting the same under section 143(l)(a) of the Act. When assessments are completed under section 143(l)(a) it cannot be said that the Assessing Officer has expressed any opinion on the correctness or otherwise of the return furnished before him. Thus there is no case of change of opinion, when there was no opinion formed at all on earlier occasions. It is also admitted fact that the a...