https://www.taxtmi.com/caselaws?id=449013 The Bombay HC held that reopening of assessment under section 147 for excessive share premium was unjustified as it constituted a mere change of opinion. The court found that the share premium issue was actively considered during original assessment proceedings, with the assessee having responded to queries raised by the Assessing Officer. Citing Aroni Commercials precedent, the court ruled that once a matter is considered during assessment proceedings, reopening based on the same issue amounts to impermissible change of opinion rather than valid reasons to believe income escaped assessment. The assessment reopening for AY 2014-15 was quashed in favor of the assessee. en-us Mon, 29 Jan 2024 00:00:00 +0530 Fri, 02 Feb 2024 13:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449013 The Bombay HC held that reopening of assessment under section 147 for excessive share premium was unjustified as it constituted a mere change of opinion. The court found that the share premium issue was actively considered during original assessment proceedings, with the assessee having responded to queries raised by the Assessing Officer. Citing Aroni Commercials precedent, the court ruled that once a matter is considered during assessment proceedings, reopening based on the same issue amounts to impermissible change of opinion rather than valid reasons to believe income escaped assessment. The assessment reopening for AY 2014-15 was quashed in favor of the assessee. Case-Laws Income Tax Mon, 29 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449013