https://www.taxtmi.com/caselaws?id=207784 HC quashed the reassessment proceedings initiated under s.148 against the assessee engaged in general insurance business. It held that the original assessment under s.143(3) had explicitly examined and allowed exemptions under s.10(15), 10(23G) and 10(33), and had specifically rejected the claim under s.10(38). The reopening reasons merely asserted that exemptions under s.10 were wrongly allowed, without any fresh tangible material. HC held this amounted to a mere change of opinion, impermissible in law. Further, the Assessing Officer, having relied on a CBDT communication clarifying availability of s.10 exemptions to non-life insurers, was bound by it and could not subsequently reopen on the same basis. The s.148 notice was set aside. en-us Thu, 01 Dec 2011 00:00:00 +0530 Wed, 03 Dec 2025 11:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207784 HC quashed the reassessment proceedings initiated under s.148 against the assessee engaged in general insurance business. It held that the original assessment under s.143(3) had explicitly examined and allowed exemptions under s.10(15), 10(23G) and 10(33), and had specifically rejected the claim under s.10(38). The reopening reasons merely asserted that exemptions under s.10 were wrongly allowed, without any fresh tangible material. HC held this amounted to a mere change of opinion, impermissible in law. Further, the Assessing Officer, having relied on a CBDT communication clarifying availability of s.10 exemptions to non-life insurers, was bound by it and could not subsequently reopen on the same basis. The s.148 notice was set aside. Case-Laws Income Tax Thu, 01 Dec 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207784