Reopening could not have been done in absence of new facts coming to knowledge subsequent to original assessment proceedings

Cognizant Technology Solutions India Private Limited Vs ACIT (Madras High Court) Conclusion: In present case, the Division Bench of the Hon’ble Madras High Court provided relief to the Petitioner observing that in the absence of new facts coming to the knowledge of the Assessing Officer subsequent to the original assessment proceedings, the reopening could not have been done on the same materials. The impugned reassessment proceedings, having been done with the same set of facts which were available during the regular assessment, is to be held to be a clear case of change of opinion. Facts: ...