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Sec. 147 of Income Tax Act, 1961 - Re-assessment - In case indeed there is a mere change in opinion, the respondent will be obliged to drop the proceeding. However, to ascertain whether is a mere change of opinion or not first it has to be established that there was true and full disclosure by the petitioner and this can be demonstrated by the petitioner only before the respondent and not in a proceeding under Art.226 of the Constitution of India as scope of judicial review is very limited and it is not possible to conduct a roving enquiry on facts and accounts. Thus, Court relegated the petitioner to participate in the proceedings before the respondent by filing appropriate representations/objections within a period of thirty days and if the circumstances do not justify invocation of proviso to Section 147, the respondent shall drop the proceedings. - SESHASAYEE PAPER AND BOARDS LIMITED V/s ASSTT. CIT -  316 CTR 196 (MAD)