https://www.taxtmi.com/caselaws?id=448466 The Bombay HC quashed a notice u/s 148 for reopening assessment, finding it was based on mere change of opinion. The petitioner had received notices during original assessment proceedings seeking details of depreciation, interest on unsecured loans, and expenses, to which responses were provided. Though the assessment order lacked elaborate discussion, there was disallowance indicating the AO had considered these matters. The court held that once queries are raised and replied to during assessment, the AO is deemed to have considered them. The reopening was invalid as it constituted change of opinion rather than reasons to believe income escaped assessment. en-us Mon, 15 Jan 2024 00:00:00 +0530 Thu, 29 Aug 2024 11:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448466 The Bombay HC quashed a notice u/s 148 for reopening assessment, finding it was based on mere change of opinion. The petitioner had received notices during original assessment proceedings seeking details of depreciation, interest on unsecured loans, and expenses, to which responses were provided. Though the assessment order lacked elaborate discussion, there was disallowance indicating the AO had considered these matters. The court held that once queries are raised and replied to during assessment, the AO is deemed to have considered them. The reopening was invalid as it constituted change of opinion rather than reasons to believe income escaped assessment. Case-Laws Income Tax Mon, 15 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448466