Dismissing the appeal the court held that there was no new material hence reassessment on mere change of opinion is bad in law. (AY. 2007 -08)
CIT v. Atul Ltd. (2019) 415 ITR 1 (Guj) (HC)
S. 147 : Reassessment–With in four years-Change of opinion-Loss on account of sale of stores-No new material-Reassessment is not valid.[S. 144(1)(c), 148]