HC Sets Aside Section 148/148A Notice on Grounds of Change of Opinion

Seema Gupta Vs ITO (Delhi High Court) Present writ petition has been filed challenging the order dated 30th June, 2022 passed under Section 148A(d) of the Income Tax Act, 1961 (hereinafter referred to as the ‘Act’) and the consequential notice dated 30th June, 2022 issued under Section 148 of the Act for the Assessment Year 2013-14. Learned counsel for the petitioner submits that the reassessment proceeding in the case of the petitioner is clearly a case of ‘change of opinion’. In support of his submission, he draws this Court’s attention to the original assessment proceedings, which...