https://www.taxtmi.com/caselaws?id=751020 The Bombay HC held that reopening assessment under Section 148 was invalid as it was based solely on a CIT order under Section 263 that was subsequently set aside by ITAT. The court found that without the CIT order, the AO lacked information to establish escaped income and had no basis for reopening. Since the petitioner had fully disclosed all relevant information during original assessment and the AO had already given effect to the ITAT order, the reopening constituted an impermissible change of opinion. The court quashed notices under Sections 148A(b), 148A(d), and 148, ruling in favor of the assessee. en-us Thu, 28 Mar 2024 00:00:00 +0530 Fri, 12 Jul 2024 12:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751020 The Bombay HC held that reopening assessment under Section 148 was invalid as it was based solely on a CIT order under Section 263 that was subsequently set aside by ITAT. The court found that without the CIT order, the AO lacked information to establish escaped income and had no basis for reopening. Since the petitioner had fully disclosed all relevant information during original assessment and the AO had already given effect to the ITAT order, the reopening constituted an impermissible change of opinion. The court quashed notices under Sections 148A(b), 148A(d), and 148, ruling in favor of the assessee. Case-Laws Income Tax Thu, 28 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751020