https://www.taxtmi.com/caselaws?id=760555 Gujarat HC quashed reopening notice u/s 148 for AY 2016-17. Assessee's return was scrutinized under s 143(3) after providing complete details regarding s 80IC deduction claim following merger. Assessment was completed accepting the return. Revenue later issued s 148 notice claiming undertaking became ineligible for s 80IC benefit post-merger under s 80IA(12) read with s 12A. HC held reopening constituted mere change of opinion as assessee had fully disclosed all material facts during original assessment and responded to queries. No reason to believe income escaped assessment existed. Petition allowed, notice quashed. en-us Mon, 30 Sep 2024 00:00:00 +0530 Wed, 23 Oct 2024 08:19:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760555 Gujarat HC quashed reopening notice u/s 148 for AY 2016-17. Assessee's return was scrutinized under s 143(3) after providing complete details regarding s 80IC deduction claim following merger. Assessment was completed accepting the return. Revenue later issued s 148 notice claiming undertaking became ineligible for s 80IC benefit post-merger under s 80IA(12) read with s 12A. HC held reopening constituted mere change of opinion as assessee had fully disclosed all material facts during original assessment and responded to queries. No reason to believe income escaped assessment existed. Petition allowed, notice quashed. Case-Laws Income Tax Mon, 30 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760555