https://www.scconline.com/blog/post/2019/08/26/del-hc-reopening-of-assessment-based-on-a-change-of-opinion-by-assessing-officer-held-vitiated-in-law-as-it-does-not-satisfy-legal-requirement-of-s-147-ita/
Del HC | Reopening of assessment based on a change of opinion by Assessing Officer held vitiated in law as it does not satisfy legal requirement of S. 147 ITA