Reopening cannot be proposed on the basis of change of opinion

Lokhandwala Construction Industries Private Limited Vs DCIT (Bombay High Court) Once a query is raised during assessment proceedings and assessee has replied to it, it follows that the query raised was a subject matter of consideration of the Assessing Officer while completing the assessment. It is not necessary that an assessment order should contain reference and/or discussion to disclose its satisfaction in respect of the query raised. In this case, during the original assessment proceedings, a notice dated 19th October 2019 was issued under Section 142(1) of the Act by which petitioner was...