ITAT and High Court agree: Reopening tax assessment u/s 143(1) improper, based solely on change of opinion.

Reopening of assessment - return filed was processed u/s 143(1) - ITAT was right that the reopening was based merely on a change of opinion. Not only did he examine the records but came to the conclusion that "there was prima facie no evidence that the liabilities were not ascertained liabilities." - HC .....

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