A change of opinion cannot be the basis of reopening the completed assessment

JRS Pharma and Gujarat Microwax Private Limited Vs DCIT (Gujarat High Court) Question of law: whether the revenue is justified in reopening the assessment for the year under consideration? Writ application filed before the Hon’ble HC of Gujrat challenging notice u/s 148 of the Income Tax Act, 1961 for reopening the assessment for AY 2013-14. During the FY 2012-13, the assessee company had entered into various international transactions with its associated enterprises for which the company had duly furnished Form 3CEB as required under Section 92E of the Act determining the Arm’s Length Pri...