Reassessment based on Materials already available during Regular Assessment is invalid

The Tinplate Company of India Ltd Vs DCIT (Calcutta High Court) Introduction: The Calcutta High Court recently delivered a significant judgment in the case of The Tinplate Company of India Ltd Vs DCIT, challenging the legality of a notice under Section 148 of the Income Tax Act, 1961. The court held that the notice and proceedings under Section 147 are not sustainable, primarily due to a perceived change of opinion by the assessing officer. Detailed Analysis: The court scrutinized the reasons for reopening the assessment, highlighting the assessing officer’s claim that the company had de...