Notice to reopen tax assessment quashed; no fresh material, merely a change of opinion.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....The HC quashed the notice issued u/s 147 for reopening of assessment. There was no tangible material to form a belief of income escaping assessment. The reasons recorded merely reflected a change of opinion which is impermissible. All material facts were duly disclosed by the petitioner during the original assessment proceedings. The reopening notice was thus held to be invalid and set aside.....