Palco Recycle Industries Ltd. v. Dy. CIT (2024) 296 Taxman 44 (Guj.)(HC)

S. 147:Reassessmet-After the expiry of four years-Change of opinion cannot be a reason to reopen the assessment.[S. 35D, 148, Art. 226]

Held when all the facts were correctly disclosed and were on record during the assessment proceedings under section 143(3) for the relevant assessment year, and the assessing office did not consciously tax the income which was now sought to be looked into by reopening the assessment under section 147, it was the clear case of change of opinion, and hence reassessment order was to be quashed and set aside. (AY. 2014-15)