Reassessment based on same material examined in regular assessment is erred in law

Hindustan Marble Pvt. Ltd. Vs Asst. CIT (Gujarat High Court) Gujarat High Court held that change of opinion on the part of the Assessing Officer acting on the same material which was examined by him in the regular assessment is erred in law. Facts- Post completion of regular assessment, notice under section 148 of the Income Tax Act was issued proposing reassessment of the total income of the petitioner. The said notice is brought under challenge vide this petition. Conclusion- It was the case of clear change of opinion on part of the Assessing Officer in exercising powers to reopen the assess...