https://www.taxtmi.com/caselaws?id=445617 The Bombay HC held that reopening of assessment under Section 147 based on internal audit objection was impermissible. The court ruled that "information" under Section 148 means only objections raised by the Comptroller and Auditor General of India, not internal audit objections. Since the basis for reopening didn't fall within the statutory definition of "information," it constituted an impermissible change of opinion. The assessment reopening was therefore invalid and the decision favored the assessee. en-us Wed, 08 Nov 2023 00:00:00 +0530 Wed, 13 Dec 2023 14:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445617 The Bombay HC held that reopening of assessment under Section 147 based on internal audit objection was impermissible. The court ruled that "information" under Section 148 means only objections raised by the Comptroller and Auditor General of India, not internal audit objections. Since the basis for reopening didn't fall within the statutory definition of "information," it constituted an impermissible change of opinion. The assessment reopening was therefore invalid and the decision favored the assessee. Case-Laws Income Tax Wed, 08 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445617