High Court Quashes Tax Assessment Notice; Approval Under Wrong Section and Based on Change of Opinion.

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....Validity of reopening of assessment - High Court quashed the notice on the ground that, (a) that approval for issuance of notice under Section 148A(d) of the Act has not been properly obtained and hence the order passed thereunder and consequent notice issued under Section 148 of the Act have to be quashed and set aside. The sanction ought to have been granted under Section 151(ii) and not under Section 151(i) of the Act. - (b) The notice to reopen has also been issued on the basis of change of opinion which is not permissible - HC....