Bench: S.SUJATHA,HANCHATE SANJEEVKUMAR
197(SC) as well as in the case of Income Tax Officer v. Techspan India (P) Ltd., reported in (2018) 92 taxmann.com 361(SC) submitted that to ascertain whether reopening is on change in opinion, it is required to verify whether the - 8 - assessment earlier made has either expressly or by necessary implication expressed an opinion on a matter which