Allowing the petition the Court held that, since assessee had made full disclosure of all material facts at time of assessment, initiation of reassessment proceedings merely on basis of change of opinion was not justified. (AY. 2010-11)
ITO v. Sanjeev Ghei. (2019) 104 taxmann.com 80/ 262 Taxman 265 ( Delhi) (HC) Editorial : SLP of revenue is dismissed; ITO v. Sanjeev Ghei. (2019) 262 Taxman 264 (SC)
S. 147 : Reassessment – Change of opinion- Loans or advances to share holders – Disclosed material facts- Reassessment is held to be not valid. [S.2(22)(e), 148 ]