Rasun Exports Private Limited, ... vs Dy. Commissioner Of Income Tax , ... on 10 June, 2021
Thus the reopening is merely on a change of opinion of the Assessing
Officer and he should have tangible material for forming an opinion
that there has been an escapement of income. 'Reason to believe' will
not include mere change of opinion. Respectfully following the ratio
laid down by the Delhi High Court in the case of Kelvinator of India
Ltd. [2002] 256 ITR 1/123 Taxman 433, the order of the
Commissioner (Appeals) in treating the reassessment made by the
Assessing Officer as null and void, deserved to be upheld.