Section 147 of Income Tax Act, 1961— In the instant case, AO has issued notice within 4 years and AO has recorded detailed reasons and came to the conclusion that there is an escapement of income on the ground that falsification of books of account and also manipulation of accounts for the last several years as well as the statement given by the Chairman Shri Ramalinga Raju and material evidence, which are necessary to be considered, were not at all considered by the AO while passing the order u/s 143(3) of the Act. After going through the reasons recorded by the AO and material available on record, we find that the AO after recording the detailed reasons, reopened the assessment and, therefore, the question of change of opinion does not arise because the assessee has not expressed any opinion at all. Thus, we find that the AO has rightly reopened the assessment.

Held that— We, therefore, uphold the reopening of assessment made by the AO u/s 147 of the Act. Accordingly, the grounds raised by the assessee on this issue are dismissed.[ELEM INVESTMENTS PVT. LTD., HYDERABAD., FINCITY INVESTMENTS PVT. LTD., HYDERABAD., HIGHGRACE INVESTMENTS PVT. LTD., HYDERABAD. VERSUS ASST, COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE – 8, HYDERABAD.] [2019] 20 ITCD Online (9) [ITAT HYDERABAD]