Reassessment proceeding u/s. 148 quashed as based on change of opinion

Tata Communications Limited Vs DCIT (Bombay High Court) Bombay High Court while quashing reassessment proceedings under section 148 of the Income Tax Act held that in the absence of any fresh tangible material, reassessment proceedings amounts to change of opinion for reviewing the earlier order, which is not permissible under the Act. Facts- The petitioner filed its return of income u/s 139(1) of the Act on 24 November 2014 which was subsequently revised on two occasions namely on 17 March 2016 and 25 March 2016 which was further modified on 29 November 2016. The revised return of income was ...