Section 147 & 148 of the Income Tax Act, 1961 — Reassessment — Since the  intimation under section 143(1) is not assessment within the meaning of the statute, there was no question of treating the reassessment as based on change of opinion ,therefore, the AO had rightly reopened the assessment after being satisfied that the income chargeable to tax had escaped assessment and it was for the AO to take appropriate remedial action and to bring the escaped income to assessment and not for the assessee to dictate the terms — Arihant Constructions vs. Assistant Commissioner of income tax [2020] 77 ITR (trib) 171(Vishakhapatnam)