Mere change of opinion does not provide jurisdiction for re-opening of assessment

Survival Technologies Pvt. Ltd. Vs DCIT (Bombay High Court) The Hon’ble Bombay High Court in Survival Technologies Pvt. Ltd. v. the Deputy Commissioner of Income Tax [Writ Petition No. 3035 of 2022 dated February 20, 2023] has set aside the notice issued under Section 148 of the Income Tax Act (“the IT Act”) seeking to reopen the assessment of the assessee and the consequential order rejecting the  objections of the assessee for reopening such assessment proceedings, on the grounds that the Facts: Survival Technologies Pvt. Ltd. (“the Petitioner”) filed its return of income for the ...