#Section 147
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View contrary to the earlier view taken by the Assessing Officer while completing the original assessment amounts to change of opinion
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Notice u/s. 148(1) of IT Act when a valid return was pending assessment
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Proceedings u/s. 147 / 148 do not set aside original proceedings
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Assessment can not be reopened for change of opinion U/s. 147 of the Income Tax Act, 1961
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Bona fide reason to believe that there is escapement of income is sufficient for issue of notice under section 148
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Power of Commissioner under section 263 of Income-tax Act
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Haryana Acrylic Manufacturing Company Vs. CIT (Delhi High Court) (2009) 308 ITR 38 (Del)
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AO can make addition on ground other then on which he re-opened the Assessment
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It cannot be said that AO has not applied his mind when all material was placed by Assessee before him
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