IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO. 489/2010 The Commissioner of Income Tax II Appellant Vs. M/s Indisoft Consultancy Services Pvt.Ltd. Respondent Mr.P.S.Sahadevan for appellant None for Respondent CORAM-J.P.DEVADHAR AND MRS.MRIDULA BHATKAR ,JJ DATE - 18TH JANUARY,2011. P.C. . Counsel for the Revenue states that he is not in a position to demonstrate that the Tribunal was wrong in holding that the reopening of the assessment is based on mere change of opinion. In these circumstances we have no option but to dismiss the appeal. (MRS.MRIDULA BHATKAR,J.) (J.P.DEVADHAR,J.)