2014 (9) TMI 1080

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....NT An affidavit of service is on record. None appears for the Income Tax Department. The notice under challenge is dated 21st November, 2013. It is issued under section 148 of the Income Tax Act, 1961, invoking powers under section 147. According to this notice, the income with regard to which the writ petitioner was chargeable to tax for the assessment year 2008-2009 had escaped assessment.....

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....were before the assessing officer and the appellate authorities, in my opinion. Nothing is mentioned in the said letter of the department which can be said to be new and could not be known to them in spite of due diligence at the time of making the assessment. There is no scope of reopening an assessment on a mere change of opinion. On identical facts, the Hon'ble High Court of Gujarat pronounced ....