Reassessment notice under Section 148 quashed as disclosed bad debt expenditure cannot justify reopening based on change of opinion

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....The HC quashed the reassessment notice issued under Section 148 for AY 2013-14, ruling that the basic requirement of "failure to disclose" was not satisfied. The assessee had disclosed expenditure towards bad debts written off in the profit and loss account, though it was also shown as provisions in the trial balance. The AO had originally considered this very ground while passing the assessment order dated 24.2.2016. The court held that the reopening notice was based on mere change of opinion, which does not constitute valid reason to believe that income chargeable to tax has escaped assessment. The petition was decided in favour of the assessee, establishing that disclosed information cannot form basis for reassessment proceedings.....