https://www.taxtmi.com/caselaws?id=767335 The Gujarat HC held that reopening of assessment was impermissible as it constituted a mere change of opinion. The revenue authorities failed to demonstrate possession of new information or tangible material suggesting income escapement. The original assessment under Section 143(3) had already considered the Section 54B deduction claim with all relevant documents provided by the assessee. The court ruled that Section 148 notice must be based on reasons to believe having direct nexus with new information, not on grounds that the original Assessing Officer inadequately inquired. The reopening was quashed in favor of the assessee. en-us Mon, 16 Dec 2024 00:00:00 +0530 Sat, 15 Mar 2025 08:41:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767335 The Gujarat HC held that reopening of assessment was impermissible as it constituted a mere change of opinion. The revenue authorities failed to demonstrate possession of new information or tangible material suggesting income escapement. The original assessment under Section 143(3) had already considered the Section 54B deduction claim with all relevant documents provided by the assessee. The court ruled that Section 148 notice must be based on reasons to believe having direct nexus with new information, not on grounds that the original Assessing Officer inadequately inquired. The reopening was quashed in favor of the assessee. Case-Laws Income Tax Mon, 16 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767335