Reassessment Unjustified: Court Rules Change of Opinion Invalid for Reopening Tax Assessment.

Validity of Reassessment proceedings - reason to believe escapement of income - The High Court agreed with the petitioner's contention that the reasons provided by the Assessing Officer indicated a clear case of change of opinion. The expenses in question had been considered and allowed during the assessment proceedings, and reopening the assessment based on the same grounds was unjustified. .....

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