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“change of opinion”

ReassessmentSection 147Section 1472,292 judgments

The decision most relied on for change of opinion is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on change of opinion

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

CIT v. Kelvinator of India Ltd.
256 ITR 1 · 2002 · High Court
439
citing judgments

An Assessing Officer cannot reopen an assessment under Section 147 based on a mere change of opinion regarding the same material available during the original assessment. Reopening requires fresh, tangible material or information that leads to a reason to believe income has escaped assessment.

T.S. Balaram ITO v. Volkart Bros.
82 ITR 50 · 1971 · Supreme Court
382
citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

CIT v. Foramer France
264 ITR 566 · 2003 · Supreme Court
253
citing judgments

Reassessment proceedings initiated under Section 147 beyond four years from the end of the relevant assessment year are invalid unless the assessee failed to disclose fully and truly all material facts necessary for assessment. Without such failure, the notice issued under Section 148 is time-barred and without jurisdiction.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

CIT v. SFIL Stock Broking Ltd.
325 ITR 285 · 2010 · High Court
243
citing judgments

Reassessment proceedings under Section 147 are invalid and void ab initio if initiated based on 'borrowed satisfaction' without the Assessing Officer's independent application of mind, or merely on documents already available on record without fresh tangible material.

Judgments citing change of opinion

Anil Tilakraj Mehra, Mumbai vs. Income Tax Officer, Mumbai

In the result, appeal in ITA No

ITA 2015/MUM/2024[2008-2009]Status: DisposedITAT Mumbai12 Jul 2024AY 2008-2009

Bench: Shri Prashant Maharshi & Shri Anikesh Banerjee

For Appellant: Shri Om KandalkarFor Respondent: Shri Manoj Kumar Sinha(CIT DR)
Section 143(2)Section 143(3)Section 147Section 250Section 44ASection 6

order passed by the learned A.O. should be quashed. On the ground that the assessment could not have been reopened on mere change of opinion. v)The learned A.O. and the learned C.I.T.(A) do not have power to travel beyond the provisions contained in the Income

Anil Tilakraj Mehra, Mumbai vs. Income Tax Officer 20(1)(1), Mumbai

In the result, appeal in ITA No

ITA 2014/MUM/2024[2009-2010]Status: DisposedITAT Mumbai12 Jul 2024AY 2009-2010

Bench: Shri Prashant Maharshi & Shri Anikesh Banerjee

For Appellant: Shri Om KandalkarFor Respondent: Shri Manoj Kumar Sinha(CIT DR)
Section 143(2)Section 143(3)Section 147Section 250Section 44ASection 6

order passed by the learned A.O. should be quashed. On the ground that the assessment could not have been reopened on mere change of opinion. v)The learned A.O. and the learned C.I.T.(A) do not have power to travel beyond the provisions contained in the Income

Anil Tilakraj Mehra, Mumbai vs. Income Tax Officer 20(1)(1), Mumbai

In the result, appeal in ITA No

ITA 2013/MUM/2024[2010-2011]Status: DisposedITAT Mumbai12 Jul 2024AY 2010-2011

Bench: Shri Prashant Maharshi & Shri Anikesh Banerjee

For Appellant: Shri Om KandalkarFor Respondent: Shri Manoj Kumar Sinha(CIT DR)
Section 143(2)Section 143(3)Section 147Section 250Section 44ASection 6

order passed by the learned A.O. should be quashed. On the ground that the assessment could not have been reopened on mere change of opinion. v)The learned A.O. and the learned C.I.T.(A) do not have power to travel beyond the provisions contained in the Income

Anil Tilakraj Mehra, Mumbai vs. Income Tax Officer 20(1)(1), Mumbai

In the result, appeal in ITA No

ITA 2011/MUM/2024[2011-12]Status: DisposedITAT Mumbai12 Jul 2024AY 2011-12

Bench: Shri Prashant Maharshi & Shri Anikesh Banerjee

For Appellant: Shri Om KandalkarFor Respondent: Shri Manoj Kumar Sinha(CIT DR)
Section 143(2)Section 143(3)Section 147Section 250Section 44ASection 6

order passed by the learned A.O. should be quashed. On the ground that the assessment could not have been reopened on mere change of opinion. v)The learned A.O. and the learned C.I.T.(A) do not have power to travel beyond the provisions contained in the Income

Dy. C.I.T. Central Cir.-1(3), Nagpur vs. M/S Spacewood Furnishers Pvt. Ltd, Nagpur

In the result, Revenue’s appeal is dismissed

ITA 163/NAG/2019[2013-14]Status: DisposedITAT Nagpur11 Jul 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Abhay AgrawalFor Respondent: Shri Abhay Y. Marathe
Section 143(3)Section 154

during the course of assessment proceedings, provisions of section 154 cannot be invoked for making disallowance of same expense which will amounts to change of opinion or review which is not permissible under the Act. 5.6 The powers of AO while invoking section 154 are restricted to make only those

Assistant Commissioner of Income Tax, Circle-3(4), Mumbai vs. Union Bank of India, Mumbai

ITA 1959/MUM/2024[2016-17]Status: DisposedITAT Mumbai11 Jul 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Respondent: Mr. Ankush Kapoor, CIT-DR
Section 115JSection 143(3)Section 144BSection 148

case and in law, the Id. CIT(A) erred in upholding the reopening proceedings even when the reopening was only based on a change of opinion. Addition on account of opening balance of FCTR 3.1 On the facts and in the circumstances of the case ... filed a Paper Book containing pages 1 to 99. 8. With reference to ground No. 2 challenging reopening proceedings on the ground of ‘change of opinion', the Ld. counsel for the assessee referred reasons recorded available on page 2 and 3 of the Paper Book and submitted that

M/S Union Bank of India, Mumbai vs. Deputy Commissioner of Income Tax, Circle- Ltu 2, Mumbai

ITA 1677/MUM/2024[2016-17]Status: DisposedITAT Mumbai11 Jul 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

Section 115JSection 143(3)Section 144BSection 148

case and in law, the Id. CIT(A) erred in upholding the reopening proceedings even when the reopening was only based on a change of opinion. Addition on account of opening balance of FCTR 3.1 On the facts and in the circumstances of the case ... filed a Paper Book containing pages 1 to 99. 8. With reference to ground No. 2 challenging reopening proceedings on the ground of ‘change of opinion', the Ld. counsel for the assessee referred reasons recorded available on page 2 and 3 of the Paper Book and submitted that

M/S Union Bank of India, Mumbai vs. Deputy Commissioner of India, Circle-(Ltu)-2, Mumbai

In the result, the appeal of the a In the result, the appeal of the assessee for assessment year ssessee for assessment year

ITA 1676/MUM/2024[2017-18]Status: DisposedITAT Mumbai11 Jul 2024AY 2017-18

Bench: Shri Om Prakash Kant () & Shri Sunil Kumar Singh ()

For Respondent: Mr. C Naresh
Section 144B

erred in upholding the reopening proceedings even when the pening proceedings even when the reopening was only based on a change of opinion. reopening was only based on a change of opinion. M/s Union Bank of India M/s Union Bank of India ITA Nos. 1677 & 1676/MUM/2024 1959/MUM/2024 Addition on account ... ground No. 2 challenging reopening With reference to ground No. 2 challenging reopening proceedings on the ground proceedings on the ground of ‘change of opinion’, t of ‘change of opinion’, the Ld. counsel for the assessee referred reasons recorded available on page 2 and 3 for the assessee referred reasons

Palanisamy Rani, Erode vs. PCIT-1, Coimbatore

In the result, the appeal of the assessee is allowed

ITA 1490/CHNY/2023[2017-18]Status: DisposedITAT Chennai10 Jul 2024AY 2017-18

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1490/Chny/2023 िनधा"रणवष" / Assessment Year: 2017-18 Principal Commissioner Of Palanisamy Rani, V. Income Tax, 38, Emm Road-2, Chennimalai Coimbatore. Road, Erode – 638 001. [Pan:Biqpr-2991-L] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. T. Vasudevan, Advocate ""यथ"क"ओरसे/Respondent By : Shri. V. Nandakumar, Cit सुनवाई क" तारीख/Date Of Hearing : 09.05.2024 घोषणा क" तारीख/Date Of Pronouncement : 10.07.2024 आदेश /O R D E R

For Appellant: Shri. T. Vasudevan, AdvocateFor Respondent: Shri. V. Nandakumar, CIT
Section 143(3)Section 263Section 54F

Rs.41,27,211/- as ‘long term capital gain’. Therefore, the revisional order of the Ld.PCIT is bad in law and it tantamount to change of opinion and hence prayed for quashing the same on legal ground. 8. Further, the Ld.Counsel stated that, based on the facts of the present case

Deputy Commissioner of Income Tax, Circle 41(4)(1), Mumbi, Mumbai vs. Aryan Investments, Mumbai

In the result, the appeal of the learned Assessing Officer is 07

ITA 5/MUM/2024[2014-15]Status: DisposedITAT Mumbai09 Jul 2024AY 2014-15

Bench: Shri Prashant Maharishi, Am Dy. Cit Aryan Investments Circle 41(4)(1) Opp. Kalpateru Estate, Room No.425, Kautilya Jvl Road, Vs. Bhavan, G Block, Bkc, Jogeshwari East, Bandra East, Mumbai-400 051 Mumbai-400 060 (Appellant) (Respondent) Pan No. Aarfa5365M Assessee By : Shri Anand Kanse, Ar Revenue By : Shri R.R. Makwana, Dr 05.06.2024 Date Of Hearing: Date Of Pronouncement : 09.07.2024

For Appellant: Shri Anand Kanse, ARFor Respondent: Shri R.R. makwana, DR
Section 143(3)Section 144BSection 147Section 148

reassessment order dated 31st March, 2022. The assessee challenged the reopening of assessment stating that it is 04. merely change of opinion and once the addition has already been considered same cannot be repeated. The learned CIT (A) held that the learned Assessing Officer has incorrectly taking the book profit

Income Tax Officer, Yavatmal vs. Yavatmal Dist. Co-Op. Bank Employee Co-Op. Pat Sanstha Ltd., Yavatmal

In the result, appeal filed by the Revenue’s is dismissed

ITA 359/NAG/2023[2015-16]Status: DisposedITAT Nagpur08 Jul 2024AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe
Section 142(1)Section 143(2)Section 147Section 148Section 56Section 80P(2)(a)Section 80P(2)(d)

grounds:– “1. Whether on facts and circumstances of the case, the Id. CIT(A) was justified in holding that this a case of change of opinion without establishing that the AO had formed an opinion during the course of assessment proceedings that interest income from investments was operational in nature

Income Tax Officer, Yavatmal vs. Shri Agrasen Nagari Sahakari Patsanstha Ltd., Yavatmal

In the result, appeal filed by the Revenue’s is dismissed

ITA 351/NAG/2023[2014]Status: DisposedITAT Nagpur08 Jul 2024

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Pravin GandhiFor Respondent: Shri Abhay Y. Marathe
Section 147Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(2)(i)

grounds:– “1. Whether on facts and circumstances of the case, the Id. CIT(A) was justified in holding that this a case of change of opinion without establishing that the AO had formed an opinion during the course of assessment proceedings that interest income from investments was operational in nature

Malligeswari Jayamohan, Chennai vs. ACIT Non Corporate Circle 15(1), Chennaiq

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 810/CHNY/2024[2012-13]Status: DisposedITAT Chennai08 Jul 2024AY 2012-13

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 810/Chny/2024 िनधा"रणवष" / Assessment Year: 2012-13 The Assistant Commissioner Of Malligeswari Jayamohan, V. Income Tax, No. 31/37, Non-Corporate Circle -15(1), Ashtalakshmi Garden, Chennai. Besant Nagar, Chennai – 600 090. [Pan: Aacpj-6285-A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Dr. L. Natrajan Ca : Shri. G. Suresh, Jcit ""यथ"क"ओरसे/Respondent By सुनवाईकीतारीख/Date Of Hearing : 08.07.2024 घोषणाकीतारीख/Date Of Pronouncement : 08.07.2024 आदेश /O R D E R Per S. R. Raghunatha:

For Appellant: Dr. L. Natrajan CA
Section 143(3)Section 147Section 148

grounds of appeal of the assessee are : 1. Reopening of assessment U/s.147 was bad in law, based on the audit objection, which is change of opinion of the AO. :-2-: ITA. No:810/Chny/2024 2. The Ld. CIT(A) erred in confirming the addition of Rs.1,50,75,797/- without considering

Hbc Lifesciences Private Limited, Gandhinagar vs. The Pr. CIT-3, Ahmedabad

In the result, appeal preferred by the assessee is allowed

ITA 328/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad05 Jul 2024AY 2018-19

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 328/Ahd/2023 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2018-19) िनधा"रण वष" Hbc Lifesciences Private Principal Commissioner बनाम बनाम/ बनाम बनाम Limited Of Income Tax-3 Vs. B-218, Mayur House, Ahmedabad G.I.D.C., Electronic Estate Sector-25, Gandhinagar, Gujarat, 382016 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacch1407M (Appellant) .. (Respondent) Shri S. N. Soparkar, Sr. Advocate & अपीलाथ" ओर से /Appellant By : Shri Parin Shah, A.R. ""यथ" क" ओर से/Respondent By : Dr. Darsi Suman Ratnam, Cit. Dr 20/06/2024 Date Of Hearing Date Of Pronouncement 05/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The Principal Commissioner Of Income Tax-3, Ahmedabad, (In Short The ‘Pcit’) Dated 25.03.2023 In Exercise Of The Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act” In Short], For The Assessment Year 2018-19. 2. The Brief Facts Of The Case Are That The Return Of Income For A.Y. 2018-19 Was Filed By The Assessee On 30.10.2018 Declaring

For Appellant: Shri Parin Shah, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT. DR
Section 143(3)Section 263Section 37Section 37(1)

course of assessment proceeding rather the entire foundation of the order u/s 263 of the Act is found to be based on change of opinion. As per the provision of Section 263 of the Act, the Ld. PCIT is empowered to conduct further enquiry as deemed necessary, but no such ... vs.Pr.CIT] A.Y. 2018-19 - 12 – the claim. The powers under Section 263 of the Act cannot be exercised only on the basis of change of opinion. It had to be first established that order was erroneous and prejudicial to the interest of the revenue and, this condition is not found

The DCIT, Gandhinagar Circle, Gandhinagar vs. Shri Jayantibhai S Patel, Ahmedbad

In the result, appeal preferred by the Revenue is dismissed

ITA 1093/AHD/2019[2010-11]Status: DisposedITAT Ahmedabad05 Jul 2024AY 2010-11

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 1093/Ahd/2019 ("नधा"रण वष" / Assessment Years : 2010-11) Dy.Cit Shri Jayantibhai S. Patel बनाम/ Gandhinagar Circle, 48, Shankar Society, Part- Vs. Gandhinagar 1, Ahmedabad, Gujarat - 382424 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Adgpp8465R (Appellant) .. (Respondent) Shri Atul Pandey, Sr. Dr अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Shri M. K. Patel, Ar 24/06/2024 Date Of Hearing Date Of Pronouncement 05/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: The Present Appeal Is Filed By The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals), Gandhinagar, (In Short ‘The Cit(A)’) Dated 02.04.2019 For The Assessment Year 2010-11. 2. This Appeal Is Against Third Round Of Assessment Completed Under Section 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) In This Case. The Brief Facts Of The Case Are That The Return Of Income For A.Y.2010-11 Was Filed By

For Respondent: Shri M. K. Patel, AR
Section 143Section 143(3)Section 147Section 2(22)(e)

legal ground as raised by the assessee. The Ld. CIT(A) had only considered the sufficiency of information and the issue of change of opinion on the part of the AO but the basic question of there being no failure on the part of the assessee was not examined

Uma Maheswara Rao Bodapati, Hyderabad vs. DCIT., Circle 2(1), Hyderabad

ITA 292/HYD/2024[2016-17]Status: DisposedITAT Hyderabad03 Jul 2024AY 2016-17

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No. 292/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Uma Maheshwara Rao Vs. Dy. C. I. T. Bodapati, Circle 2(1) Hyderabad Hyderabad Pan:Atnpb5755D (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Adv. T. Chaitanya Kumar राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 13/06/2024 घोषणा की तारीख/Pronouncement: 03/07/2024 आदेश/Order

For Appellant: Adv. T. Chaitanya KumarFor Respondent: : Shri Shakeer Ahmed, DR
Section 143(3)Section 148Section 50C

assessee challenged the reopening of the assessment on the ground that the Assessing Officer has reopened the assessment on mere change of opinion which is evident from the original assessment order passed by the Assessing Officer u/s 143(3) of the Act where the Assessing Officer has considered the issue

M/S. Datta Dairy Products Pvt. Ltd., Buldhana vs. ITO, Ward-1, Khamgaon

In the result, the appeal filed by the assessee is allowed

ITA 96/NAG/2021[2011-12]Status: DisposedITAT Nagpur02 Jul 2024AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Miss. J.S.Thakar, AdvocateFor Respondent: Shri Abhay Y. Marathe, Sr. DR
Section 143(3)Section 250Section 56(2)(ix)

year in question A.Y. 2011-12 on merits but failed to appreciate that the reassessment being itself without jurisdiction as based on mere change of opinion, there was no scope nor any legal sanctity for making/retaining addition of Rs.22,00,000/- as income from other sources for the year ... accepting NIL income as returned. Above letters dt. 14.08.2012, dt. 15.05.2013 and 143(3) order dt. 19.08.2013 are enclosed herewith. Thereafter on some change of opinion or some audit objection the A.O. issued notice u/s.148 on 22.12.2015. A.O. on above facts treated the above referred transaction which was cancelled

Jel Fianance & Investments Limited, (Formerly Known As Jubiliant Engineering Limited), Hyd, Secunderabad vs. DCIT, Circle-2(1), Hyderabad

The appeal of the assessee is dismissed

ITA 867/HYD/2017[2008-09]Status: DisposedITAT Hyderabad28 Jun 2024AY 2008-09

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdia

For Appellant: Shri M.V. Anil Kumar , AdvocateFor Respondent: : Ms. Sheetal Sarin, DR
Section 10BSection 115JSection 143Section 147Section 148Section 28

escaped assessment. In the absence of both tangible material and reason to believe that income had escaped assessment, it is only a mere change of opinion. It is also submitted that during the original assessment the then Ld. AO had disallowed certain expenditure and recomputed the deduction under section ... undertaking being an 100% EOU unit. Therefore, issue of notice under section 148 based on the information on record amounts to change of opinion. Further the Ld. AR prayed that the issue of notice under section 148 is bad in law and the assessment may be quashed. 6. Per contra

Income Tax Officer, Ward-2(1)(1), Bengaluru vs. G. Tex Inc, Bengaluru

In the result, the appeal filed by the revenue is dismissed

ITA 1129/BANG/2023[2011-12]Status: DisposedITAT Bangalore26 Jun 2024AY 2011-12

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year : 2011-12

For Appellant: Shri Hemanth, CAFor Respondent: Shri V. Parithivel, JCIT-DR
Section 142(1)Section 143(3)Section 148Section 195Section 195(1)Section 250Section 40

profit and loss account and allowed the overseas commission expenses of Page 4 of 9 Rs.3,00,25,255/- but on the change of opinion, the Ld.AO initiated the proceeding u/s. 148 of the IT Act which is not permissible under the law. Further, the Ld.AR of the assessee vehemently

Nikunj Dhanuka, Kolkata vs. DCIT, Cir. 32, Kolkata

In the result, appeal of the assessee is allowed

ITA 345/KOL/2024[2012-13]Status: DisposedITAT Kolkata24 Jun 2024AY 2012-13

Bench: Shri Rajpal Yadav, Hon’Ble & Dr. Manish Borad, Hon’Ble

For Appellant: Shri Anil Kochar & Aryan Kochar, A.RFor Respondent: Shri Arjun Kumar Meena, Addl. CIT, Sr. D/R
Section 10(38)Section 143Section 143(3)Section 147Section 250Section 250(1)Section 250(6)Section 282

proper and it merely is a case of reason to support or I.T.A. No. 345/Kol/2024 Assessment Year: 2012-13 Nikunj Dhanuka 6 merely change of opinion. Above all, the main allegation against the assessee as per the information received from the investigation wing that the assessee had claimed exemption