https://www.taxtmi.com/caselaws?id=417481 The High Court ruled in favor of the petitioner, emphasizing that re-opening an assessment based solely on a change of opinion without tangible material is impermissible under the law. The court found that the Assessing Officer's reasons for re-opening the assessment were flawed, as they were founded on incorrect facts and a mere change of opinion. The court highlighted that if the relevant facts were already considered during the original assessment, a re-opening based on a change of opinion alone is invalid. The court quashed the notice under Section 148 of the Income Tax Act and rejected the petitioner's objections, allowing the petition with no costs. en-us Wed, 19 Jan 2022 00:00:00 +0530 Mon, 24 Jan 2022 08:53:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=417481 The High Court ruled in favor of the petitioner, emphasizing that re-opening an assessment based solely on a change of opinion without tangible material is impermissible under the law. The court found that the Assessing Officer's reasons for re-opening the assessment were flawed, as they were founded on incorrect facts and a mere change of opinion. The court highlighted that if the relevant facts were already considered during the original assessment, a re-opening based on a change of opinion alone is invalid. The court quashed the notice under Section 148 of the Income Tax Act and rejected the petitioner's objections, allowing the petition with no costs. Case-Laws Income Tax Wed, 19 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=417481