https://www.taxtmi.com/caselaws?id=250815 The Hon'ble Bombay High Court held that the Assessing Officer's reopening of the assessment solely based on a letter previously considered in the original assessment was a mere change of opinion, not a valid ground for reassessment under section 147 of the Income Tax Act. Consequently, the reopening was deemed bad in law and set aside, allowing the assessee's appeal. The issue of disallowance and capitalization of interest became academic due to the invalid reopening. The appellate tribunal emphasized the necessity of legitimate reasons for reassessment and its implications on subsequent issues raised in the appeal. en-us Wed, 20 Aug 2014 00:00:00 +0530 Tue, 26 Aug 2014 15:37:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=250815 The Hon'ble Bombay High Court held that the Assessing Officer's reopening of the assessment solely based on a letter previously considered in the original assessment was a mere change of opinion, not a valid ground for reassessment under section 147 of the Income Tax Act. Consequently, the reopening was deemed bad in law and set aside, allowing the assessee's appeal. The issue of disallowance and capitalization of interest became academic due to the invalid reopening. The appellate tribunal emphasized the necessity of legitimate reasons for reassessment and its implications on subsequent issues raised in the appeal. Case-Laws Income Tax Wed, 20 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=250815