Mere change of opinion not valid for reopening of assessment u/s 148

CGS-CIMB Securities (India) P. Ltd. Vs CIT (Appeals), NFAC Mumbai (ITAT Mumbai) ITAT Mumbai held that re-opening of assessment under section 148 of the Income Tax Act on account of mere change of opinion is bad-in-law and liable to be quashed. Facts- In ROI, the Assessee had claimed software expanses of 2.61 crore, as revenue expenditure. AO held that the software expenses are capital in nature and the accordingly, disallowed the above said claim. However, AO allowed depreciation thereon@ 60%, which amounted to Rs.1.57 crore. The Assessee had challenged the above said disallowance by filing ap...