If assessments concluded are not in accordance with law, it is not change of opinion, but it is a valid reason for reopening assessments; thus where Assessing Officer had ignored mandatory provision of section 14A and Circular No. 5/14 while completing assessments, reopening of assessment was justified – T.K. Salim v. Union of India – [2024] 163 taxmann.com 385 (Kerala)
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