Dismissing the appeal of the revenue the Court held that the reassessment proceedings were initiated on the basis of the same material which was available before the Assessing Officer and a mere change of opinion had led to the reassessment, which was not permissible. ( AY.2007 -08)
CIT v. Balaji Neemuch Infrastructure Pvt. Ltd. (2019) 414 ITR 707 (MP)(HC)
S. 147 : Reassessment –With in four years- Change of opinion- No new material-Reassessment is held to be bad in law . [ S.80IA(4 ]