https://www.taxtmi.com/caselaws?id=448740 Bombay HC allowed petition challenging reopening of assessment under Section 147 of Income Tax Act, 1961. Petitioner had responded to all queries during original assessment proceedings, and AO passed assessment order after considering all material. Court held that reopening was based on change of opinion rather than tangible material showing income escapement. Since queries were already raised and answered during original proceedings, and returned income was accepted without disallowances for multiple assessment years, no valid reasons existed to believe income had escaped assessment. Reopening on basis of change of opinion is impermissible under law. en-us Tue, 23 Jan 2024 00:00:00 +0530 Fri, 12 Jul 2024 12:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448740 Bombay HC allowed petition challenging reopening of assessment under Section 147 of Income Tax Act, 1961. Petitioner had responded to all queries during original assessment proceedings, and AO passed assessment order after considering all material. Court held that reopening was based on change of opinion rather than tangible material showing income escapement. Since queries were already raised and answered during original proceedings, and returned income was accepted without disallowances for multiple assessment years, no valid reasons existed to believe income had escaped assessment. Reopening on basis of change of opinion is impermissible under law. Case-Laws Income Tax Tue, 23 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448740