Form 10 Disclosure & Reopening

Bombay High Court held that when a trust has already disclosed its accumulation purpose in Form 10, reopening under Section 147 amounts to mere change of opinion and is unsustainable. The Court emphasised that reassessment cannot be used as a review mechanism, especially when the original assessment had accepted the disclosures furnished. The ruling strengthens the principle that transparency in Form 10 filings protects assessees from arbitrary reopening.