ITAT observed that since the very basis for reopening of the assessment was based on the information already on record and since the issue was already examined by the AO during regular assessment proceedings, reopening could not be made only on the basis of change of opinion. (AY. 2008 -09)
Mylan Laboratories Ltd. v. DCIT (2018) 52 CCH 0631/ 66 ITR 354 (Hyd.)(Trib.)
S. 147 : Reassessment – Within four years – Reopening of assessment based only on the change of opinion on the existing material cannot be sustained in absence of any new tangible material.