https://www.taxtmi.com/caselaws?id=244064 The Bombay HC held that reassessment proceedings under sections 147/148 cannot be initiated based on mere change of opinion by the Assessing Officer. Where all facts were available during original assessment and queries were raised and replied to, the AO cannot reopen assessment without reasonable belief that income escaped taxation. The court emphasized that assessment orders need not contain detailed discussion of every query if the AO was satisfied with responses. The HC set aside the section 148 notice and reassessment order, ruling in favor of the assessee as the reopening was impermissible being based solely on change of opinion. en-us Tue, 11 Feb 2014 00:00:00 +0530 Fri, 20 Jun 2025 08:53:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=244064 The Bombay HC held that reassessment proceedings under sections 147/148 cannot be initiated based on mere change of opinion by the Assessing Officer. Where all facts were available during original assessment and queries were raised and replied to, the AO cannot reopen assessment without reasonable belief that income escaped taxation. The court emphasized that assessment orders need not contain detailed discussion of every query if the AO was satisfied with responses. The HC set aside the section 148 notice and reassessment order, ruling in favor of the assessee as the reopening was impermissible being based solely on change of opinion. Case-Laws Income Tax Tue, 11 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=244064