https://www.taxtmi.com/caselaws?id=755219 The Gujarat HC quashed a reassessment notice u/s 148 for AY 2017-18, ruling that the AO's reasons for reopening were merely a change of opinion. The assessee had disclosed all material facts during original assessment proceedings, and the AO had accepted the return u/s 143(3). The reasons recorded only mentioned cash deposits in bank account without reference to purchases mentioned in Investigation Department report. Following Kelvinator of India Ltd. precedent, the court held that reassessment based on change of opinion without new tangible material was invalid. The petition was allowed in favor of the assessee. en-us Fri, 14 Jun 2024 00:00:00 +0530 Mon, 08 Jul 2024 11:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755219 The Gujarat HC quashed a reassessment notice u/s 148 for AY 2017-18, ruling that the AO's reasons for reopening were merely a change of opinion. The assessee had disclosed all material facts during original assessment proceedings, and the AO had accepted the return u/s 143(3). The reasons recorded only mentioned cash deposits in bank account without reference to purchases mentioned in Investigation Department report. Following Kelvinator of India Ltd. precedent, the court held that reassessment based on change of opinion without new tangible material was invalid. The petition was allowed in favor of the assessee. Case-Laws Income Tax Fri, 14 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755219