Mere Issue of 2nd notice U/s. 148 does not constitute Change of Opinion; AO can examine genuineness of share premium U/s 68

M/s. Cornerstone Property Investments Pvt. Ltd. Vs ITO (ITAT Bangalore) Mere Issue of 2nd notice U/s. 148 does not constitute Change of Opinion The first notice issued under Section 148 of the Act on 18.4.2012 was dropped and a second notice under Section 148 of the Act was issued on 10.6.2013. This, in itself, does not constitute “Change of Opinion.” This fact comes out clearly from the Assessing Officer’s letter dt.4.6.2013 wherein the Assessing Officer has mentioned that the proceedings initiated by issue of the earlier notice under Section 148 of the Act dt.18.4.2012 was dropped as t...