Assessments cannot be reopened merely on the basis of a change of opinion without valid grounds

Upesi Ventures Ltd. Vs ACIT (Bombay High Court) The case of Upesi Ventures Ltd. vs. ACIT before the Bombay High Court revolves around the challenge to a notice issued under Section 148 of the Income Tax Act, 1961, proposing to reopen the assessment for the Assessment Year (AY) 2015-2016. The petitioner, Upesi Ventures Ltd., a company incorporated in Cyprus and registered as a Foreign Portfolio Investor with SEBI, contested the notice, arguing that it was ex facie illegal, untenable, and contrary to the provisions of the Act. The assessment for the AY 2015-2016 had been completed earlier, accep...