Reopening of assessment for mere change of opinion untenable in law

Shahlon Silk Industries Pvt Ltd Vs ACIT (Gujarat High Court) Gujarat High Court held that issued raised in reopening assessment was already considered during assessment proceedings u/s 143(3) of the Income Tax Act. Accordingly, mere change of opinion by the Assessing Officer cannot be ground for reopening of assessment. Facts- By the petition under Article 226 of the Constitution of India, the petitioner has challenged the notice issued under section 148 of the Income Tax Act, 1961 for reopening of the assessment proceedings for the Assessment Year 2012-2013. The petitioner is a company incorp...