Bench: Shri Siddhartha Nautiyal & Shri B.M. Biyani(Conducted Through Virtual Court) & C.O. No. 9/Ind/2020 Assessment Year: 2011-12 Dcit M/S Raj Rajeshwar Cotton Khandwa Corporation, बनाम/ Warla Road, Sendhwa, Vs. District - Khandwa (Appellant / Revenue) (Respondent / Assessee) Pan: Aagfr 6243 N Assessee By None Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.10.2022 Date Of Pronouncement 21.10.2022

section 147 would give arbitrary power to AO to reopen past assessments on a mere change of opinion i.e. a mere change of opinion cannot form basis for reopening a completed assessment. 4.10 In the instant case, the AO had passed the original assessment taking into account all the documents and facts of the case and again, he had reopened