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The word "reason to believe" has been construed by the Supreme Court in the matter of CIT Vs. Kelvinator India Limited reported in 320 ITR Page 561 wherein the Court has observed as under :

"However one needs to give schematic interpretation to the words "reason to believe"

failing which we are afraid Section 147 would give arbitrary powers to the Assessing officer to ASN 15/19 WP-2710.doc reopen assessment on the basis of "mere change of opinion" which cannot be per se reason to reopen. We must keep in mind the conceptual difference between power to review and power to reassess. The Assessing officer has no power to review; he has power to reassess. But reassessment is to be based of fulfillment of certain preconditions and if the concept of 'change of opinion' is removed as contended by the department then in the garb of reopening of assessment review would take place".