The Bombay High Court has held that the reopening of the assessment was purely on the basis of a change of opinion of the AO from that held earlier during the course of assessment proceedings. The.
While deciding the question as to whether reopening of a concluded assessment under Section 147 of the Income Tax Act (“Act”) was legally sustainable or not, the Supreme Court recently held that for.
The Bombay High Court has held that a change of opinion does not constitute justification and/or reasons to believe that income chargeable to tax has escaped assessment.The bench of Justice K. R..
While setting aside the order disposing of assessee s objection for re-opening of assessment pursuant to the issue of notice u/s 148 of the Income tax Act, 1961 and the consequent reassessment order,.
The Bombay High Court has held that re-opening is not permissible as it clearly falls within the purview of a ‘change of opinion’ which is impermissible in law.The bench of Justice K. R. Shriram and.