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Change of opinion reassessment...
If AO found that one addition supposed to be made was not made while completing assessment u/s 143(3)....within 4 years can he reopen the assessment u/s 148 so that he can make that addition without any new tangible material coming to his possession......
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" There was no tangible material before the Assessing Officer to form the belief that the income had escaped assessment and therefore, reopening of assessment under section 147 was not valid.
Balakrishna Hiralal Wani vs. ITO (2010) 321 ITR 519 (Bom.)"
=== Advocate Ajay R. Singh ::: Guide to the law on reopening of assessments u/s 147 of the Income-tax Act
Refer:: https://www.itatonline.org/articles_new/guide-to-the-law-on-reopening-of-assessments-us-147-of-the-income-tax-act/
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