https://www.taxtmi.com/caselaws?id=781007 HC upheld the validity of reopening assessment under s.148, finding that income from renting and sale of business premises should have been taxed as business income but was not considered in the original s.143(3) scrutiny. The AO had not formed any view on that classification during initial proceedings and had not raised or elicited relevant queries; therefore the reassessment could not be characterized as a prohibited "change of opinion." The challenge to issuance of the notice under s.148 was dismissed for lack of merit. en-us Mon, 03 Nov 2025 00:00:00 +0530 Mon, 10 Nov 2025 08:56:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781007 HC upheld the validity of reopening assessment under s.148, finding that income from renting and sale of business premises should have been taxed as business income but was not considered in the original s.143(3) scrutiny. The AO had not formed any view on that classification during initial proceedings and had not raised or elicited relevant queries; therefore the reassessment could not be characterized as a prohibited "change of opinion." The challenge to issuance of the notice under s.148 was dismissed for lack of merit. Case-Laws Income Tax Mon, 03 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781007