Initiation of reassessment in spite of full & true disclosure is untenable

Devkant Synthetics India Pvt. Ltd. Vs Additional/Joint/Deputy/Assistant Commissioner of Income Tax Officer (Bombay High Court) Bombay High Court held that initiation of reassessment proceeding under section 148 of the Income Tax Act, in absence of any failure on the part of the assessee to disclose any material facts fully and truly during the regular assessment proceedings, is mere change of opinion and hence liable to be quashed. Facts- The petitioner in the present petition challenges the reassessment proceedings initiated pursuant to a notice, dated 31st March 2022 issued u/s. 148 of the I...