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The High Court held that the reopening of assessment was invalid. Despite the amendment made in 1998 to Section 147 of the Act, reassessment proceedings cannot be initiated based on a change of opinion. The Assessing Officer (AO) had previously considered the issue of deduction u/s 54B and formed an opinion, albeit without recording reasons. The explanation provided by the petitioner was accepted, and the deduction u/s 54B was allowed. Consequently, the notice issued u/s 148 for the assessment year 2009-2010 and the order rejecting the objections were quashed by the High Court.
The High Court held that the reopening of assessment was invalid. Despite the amendment made in 1998 to Section 147 of the Act, reassessment proceedings cannot be initiated based on a change of opinion. The Assessing Officer (AO) had previously considered the issue of deduction u/s 54B and formed an opinion, albeit without recording reasons. The explanation provided by the petitioner was accepted, and the deduction u/s 54B was allowed. Consequently, the notice issued u/s 148 for the assessment year 2009-2010 and the order rejecting the objections were quashed by the High Court.
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