no reassessment on mere change of opinion

Section 145, Section 147

Bombay H.C : Where Assessing Officer being satisfied with explanation offered by assessee with regard to its claim that purchase/sale of shares offered to tax under head ‘capital gain’ was a result of investment activity passed assessment order under section 143(3) upon assessee and subsequently he reopened said assessment on plea that assessee had so manipulated its account that normal business profit in share trading was claimed as short-term capital gain so as to attract lower rate of tax, since very issue of taxability of sale of shares was considered by Assessing Officer during original assessment proceedings, entire proceeding for reopening assessment was based on change of opinion

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High Court Of Bombay Aroni Commercials Ltd. Vs. DCIT -2(1) Assessment Year : 2008-09 Section : 145, 147 Mohit S.

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