Commnr. Of Income Tax, Delhi vs M/S. Kelvinator Of India Ltd

The Supreme Court examined the interpretation of Section 147 of the Income Tax Act, 1961, particularly in light of the amendments made by the Direct Tax Laws (Amendment) Act, 1987. The Court held that the concept of 'change of opinion' is not obliterated post-amendment, and the Assessing Officer must have a valid reason to believe that income has escaped assessment. The judgment clarified that the conditions for reopening assessments remain stringent, ensuring that arbitrary reassessments are avoided.