Mere change of opinion cannot be a ground for reopening of assessment

Konark Life Spaces Vs ACIT (Bombay High Court) The Hon’ble Bombay High Court in Konark Life Spaces v. Assistant Commissioner of Income -Tax and Ors. [Writ Petition No. 2840 of 2022 dated February 10, 2023] has set aside the notice issued under Section 148 of the Income Tax Act, 1961 (“the IT Act”) for re-opening of the assessment, on the grounds that the Revenue Department had neither sought any new information nor made a reference to new material on record. Held that, a change in opinion that does not satisfy the jurisdictional foundation under Section 147 of the IT Act. Facts: Konark L...