Court quashes assessment notice based on change of opinion, lacks jurisdiction.

The Supreme Court held that the notice issued for re-opening the assessment under Section 148 of the Income-Tax Act was solely based on a change of opinion, lacking jurisdiction. The High Court upheld the challenge to the notice, leading to its quashing. The Supreme Court dismissed the special leave petition, affirming the High Court's decision. Consequently, the proceedings regarding the re-opening of the assessment were concluded.

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Issues:
1. Re-opening of assessment under Section 148 of the Income-Tax Act based on a change of opinion.
2. Challenge to the issuance of notice for re-opening assessment.
3. Jurisdiction of the Assessing Officer in re-opening assessment proceedings.

Analysis:
1. The Supreme Court addressed the issue of re-opening assessment under Section 148 of the Income-Tax Act, focusing on whether the notice issued for re-opening was based on a mere change of opinion. The High Court observed that the reasons for the notice were the same as the queries raised by the Assessing Officer during the original assessment proceedings. The Court emphasized that the non-rejection of the explanation in the Assessment Order indicated the Assessing Officer's acceptance of the assessee's view, leading to the formation of an opinion. Consequently, the Court held that the reasons for the re-opening notice were solely a change of opinion, rendering it without jurisdiction in the present circumstances.

2. The challenge to the issuance of the notice for re-opening the assessment was upheld by the High Court, leading to the quashing and setting aside of the impugned notice dated 27 March 2019. The High Court's decision was based on the finding that the reasons for the notice represented a mere change of opinion on the part of the Assessing Officer, which lacked legal validity in the context of the assessment proceedings.

3. Considering the High Court's ruling and the circumstances of the case, the Supreme Court found no grounds to interfere in the matter. Consequently, the special leave petition was dismissed, affirming the High Court's decision to quash and set aside the notice for re-opening the assessment. Any pending applications were also disposed of in light of the dismissal of the special leave petition, bringing closure to the legal proceedings concerning the re-opening of the assessment under Section 148 of the Income-Tax Act.

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