https://www.taxtmi.com/caselaws?id=750712 HC set aside the reopening notice and decided for the assessee. The court found the reasons for reopening relied on the same DG GSTI report and identical material considered in the original assessment, amounting to a change of opinion rather than discovery of new material. The amended s.147 could not be invoked because it postdated the assessment and, in any event, established principles guarding against change of opinion continue to apply. Consequently the reassessment was held unsustainable and the reopening order was quashed. en-us Wed, 20 Mar 2024 00:00:00 +0530 Mon, 15 Sep 2025 15:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=750712 HC set aside the reopening notice and decided for the assessee. The court found the reasons for reopening relied on the same DG GSTI report and identical material considered in the original assessment, amounting to a change of opinion rather than discovery of new material. The amended s.147 could not be invoked because it postdated the assessment and, in any event, established principles guarding against change of opinion continue to apply. Consequently the reassessment was held unsustainable and the reopening order was quashed. Case-Laws Income Tax Wed, 20 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=750712