Reopening based on same material on which assessment order was passed is impermissible

Imperial Consultants and Securities Ltd Vs DCIT (Bombay High Court) Bombay High Court held that reopening under section 147 of the Income Tax Act based on the very material on which the assessment order was passed is impermissible in law since it merely depicts change of opinion. Facts- This petition under Article 226 of the Constitution of India challenges the legality and validity of the notice dated 31 March 2021 issued to the petitioner u/s. 148 of the Income Tax Act, 1961 and an order dated 24 February 2022 disposing of the objections filed for reopening of the assessment and the conseque...