The
petitioner thereupon raised the objections to the notice for
reopening under a communication dated 4.1.2013. It was contended
that the entire claim was examined at length in the original
assessment. Reopening, therefore, was not permissible since the same
would only be on the basis of change of opinion. The petitioner
relied on the decision of the Apex Court in the case of Commissioner
of Income-Tax vs. Kelvinator of India Ltd. reported in
[2010] 320 ITR 561 (SC)
besides other authorities of this Court in the case of Gujarat
Tea Processors & Packers Ltd. vs. Deputy Commissioner of
Income-Tax reported in
[2012](28) Taxmann.com (187)(GUJ)
and in the case of Parixit
Industries (P.)