Court :
HC
Brief :
Held by the Hon`ble Court that, what the court is required to check is whether material exists on record for the A.O. to form the "reason to believe" and mere change in opinion on an interpretation of a provision by itself without anything more can not give rise to "reason to believe". Therefore reassessment proceedings on this basis is not justified in law.
Citation :
Siemens Information Systems Ltd. Vs. A.C.I.T. And Others 10/11/2007
[2007] 295 ITR 333 (Bom)
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