AO cannot reopen an assessment even within a period of 4 years merely on the basis of a change of opinion

Glaxosmithkline Pharmaceuticals Ltd. Vs ACIT/DCIT (Bombay High Court) Admittedly, this is a case where the notice under Section 148 of the Act has been issued after the expiry of 4 years from the end of the relevant assessment year and assessment under Section 143(3) of the Act has also been completed. Hence, proviso to Section […]
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