Reassessment

Article I.                    The validity of the reopening of the assessment has to be judged on the basis of the reasons recorded for reopening of the assessment — as held by MumHC in DIT v May and Baker Ltd — In favour of: The assessee.

Article II.                 Change of opinion — AO was not justified in reopening of assessment when all the material facts were disclosed and were duly considered by the AO while making the original assessment — as held by MumHC in Sanand Properties Pvt Ltd v JCIT — In favour of: The assessee.