What is the limit of jurisdiction for re-opening a completed assessment?
Where an assessment has already been made, there could be re-assessment proceedings under Sec. 147. If there is concealment of particulars indicating conscious under-statement of income, it is possible to reopen the assessment within the six-year time limit for the past six years. If the omission had occurred for no fault of the assessee, such reopening may still be possible for four-year time limit. But where the matter has been considered in the original assessment and the assessee’s stand has been accepted by the assessing officer, he cannot review his own decision as it would amount to a change of opinion, which is not permitted even for the four-year time limit. A widespread belief in the Income-tax Department that there is wider jurisdiction in view of certain amendments from assessment year 1989-90 was found to be mistaken, since the requirement of “reason to believe” continues both prior to and after the amendment even as conceded by a Board Circular No. 549 dated October 31, 1
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