Bombay HC Quashes Reassessment U/S 147 for Change of Opinion & Review of assessment order

Pfizer Limited Vs DCIT (Bombay High Court) Bombay High Court held that initiation of reassessment proceedings under section 147 of the Income Tax Act resulting into change of opinion and review of the assessment order is not permissible in law. Accordingly, reassessment proceedings are liable to be quashed. Facts- This petition challenges notice under Section 148 of the Income-tax Act, 1961 dated 29 March 2016 for the Assessment Year (AY) 2009–10 seeking to reopen the assessment made on 18 April 2013 under Section 143 of the Act. This petition was admitted on 20 December 2016, and the impugn...