In the result, the appeal filed by the assessee is partly allowed
Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2011-12
reassessment proceedings when admittedly conditions specified u/s 147 of the ITA, 1961 for valid initiation were not satisfied in as much as all the facts were truly and fully disclosed in the original assessment proceedings and order was passed after due verification. As such, the addition was only the result of a change in opinion and the action