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HC quashed the reassessment notice issued to the petitioner under s.148 for AY 2019-20, holding the proceedings to be impermissible as a mere "change of opinion." The AO had already, on identical material arising from the same search, seizure and survey operation, accepted the version of both the petitioner and the transporter in the transporter's reassessment for AY 2019-20, namely, that no cash was returned to the petitioner against transportation bills. Initiating reassessment of the petitioner on the same transactions and information would amount to an impermissible review of the earlier decision. Consequently, the reassessment proceedings and notice were set aside.
HC quashed the reassessment notice issued to the petitioner under s.148 for AY 2019-20, holding the proceedings to be impermissible as a mere "change of opinion." The AO had already, on identical material arising from the same search, seizure and survey operation, accepted the version of both the petitioner and the transporter in the transporter's reassessment for AY 2019-20, namely, that no cash was returned to the petitioner against transportation bills. Initiating reassessment of the petitioner on the same transactions and information would amount to an impermissible review of the earlier decision. Consequently, the reassessment proceedings and notice were set aside.
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