HRY WAREHOUSING CORPORATION, vs. JOINT COMMISSIONER OF IT

Bench: MR. JUSTICE AMARINDER SINGH GREWAL,MR. JUSTICE JAGMOHAN BANSAL

section 147 would give arbitrary powers to the Assessing Officer to reopen assessments on the basis of 'mere change of opinion', which cannot be per se reason to reopen. We must also keep in mind the conceptual difference between power to review and power to reassess. The Assessing Officer has no power to review; he has the power to reassess