Allowing the petition the court held that , Claim of exemption was accepted in original assessment after scrutiny . Reassessment to withdraw Exemption on ground that some other aspects of claim was not examined will be change of opinion which is not permissible . (AY.2010-11)
Hitech Outsourcing Services. v. CIT (2018) 409 ITR 609 (Guj)(HC)
S.147: Reassessment —With in four years-Change of opinion- Claim of exemption was accepted in original assessment after scrutiny – Reassessment to withdraw Exemption on ground that some other aspects of claim was not examined will be change of opinion which is not permissible . [ S.10S, 10B, 148, 264 ]