Initiation of reassessment proceedings was not justified merely on basis of change of opinion

Where Assessing Officer initiated reassessment proceedings on ground that production of `cattle and poultry feed' could not be classified as manufacture and, therefore, claim of assessee under section 80-IB(5) was wrongly allowed, in view of fact that at time of allowing assessee's claim in original assessment proceedings all information regarding manufacturing process was available before Assessing Officer, initiation of reassessment proceedings was not justified merely on basis of change of opinion - [2010] 8 taxmann.com 232 (Cal.)