https://www.taxtmi.com/caselaws?id=773304 The HC held that a reopening notice under Section 148 was invalid as it was based on mere change of opinion rather than failure to disclose material facts. The assessee had disclosed expenditure towards bad debts in the profit & loss account, which was also shown as provisions in the trial balance. The Assessing Officer had already considered this matter during the original assessment. Since there was no failure to disclose and the reopening was based on a change of opinion, the basic requirement for issuing a reopening notice was not satisfied. The case was decided in favor of the assessee. en-us Tue, 17 Jun 2025 00:00:00 +0530 Fri, 20 Jun 2025 08:34:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773304 The HC held that a reopening notice under Section 148 was invalid as it was based on mere change of opinion rather than failure to disclose material facts. The assessee had disclosed expenditure towards bad debts in the profit & loss account, which was also shown as provisions in the trial balance. The Assessing Officer had already considered this matter during the original assessment. Since there was no failure to disclose and the reopening was based on a change of opinion, the basic requirement for issuing a reopening notice was not satisfied. The case was decided in favor of the assessee. Case-Laws Income Tax Tue, 17 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773304