https://www.taxtmi.com/caselaws?id=761044 Gujarat HC held that reopening assessment under Section 147 based on mere change of opinion is not permissible. The court found that the agricultural land sale transaction was already scrutinized during regular assessment with full details provided by assessee. Despite notice being issued within four years, the AO cannot assume jurisdiction on same facts with different opinion. Following Supreme Court precedent in Commissioner of Income Tax v. Kelvinator of India Ltd., the court emphasized that reassessment requires fulfillment of pre-conditions and change of opinion concept serves as built-in test against abuse of power. Assessment reopening was quashed in favor of assessee. en-us Tue, 15 Oct 2024 00:00:00 +0530 Mon, 04 Nov 2024 08:12:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761044 Gujarat HC held that reopening assessment under Section 147 based on mere change of opinion is not permissible. The court found that the agricultural land sale transaction was already scrutinized during regular assessment with full details provided by assessee. Despite notice being issued within four years, the AO cannot assume jurisdiction on same facts with different opinion. Following Supreme Court precedent in Commissioner of Income Tax v. Kelvinator of India Ltd., the court emphasized that reassessment requires fulfillment of pre-conditions and change of opinion concept serves as built-in test against abuse of power. Assessment reopening was quashed in favor of assessee. Case-Laws Income Tax Tue, 15 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761044