https://www.taxtmi.com/caselaws?id=760983 The Gujarat HC quashed a notice issued under section 148 for reopening assessment under section 147. The court held that the AO could not assume jurisdiction to reopen assessment based merely on perusal of assessment records without fresh tangible material not previously considered during regular assessment proceedings under section 143(3). The AO's action constituted a mere change of opinion, which is impermissible. Following the Supreme Court precedent in Kelvinator of India Ltd., the petition was allowed and the impugned notice was set aside. en-us Tue, 22 Oct 2024 00:00:00 +0530 Wed, 30 Oct 2024 08:32:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760983 The Gujarat HC quashed a notice issued under section 148 for reopening assessment under section 147. The court held that the AO could not assume jurisdiction to reopen assessment based merely on perusal of assessment records without fresh tangible material not previously considered during regular assessment proceedings under section 143(3). The AO's action constituted a mere change of opinion, which is impermissible. Following the Supreme Court precedent in Kelvinator of India Ltd., the petition was allowed and the impugned notice was set aside. Case-Laws Income Tax Tue, 22 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760983