Reopening of assessment quashed as based on change of opinion: Bombay HC

Prithvi Apartments Co-operative Housing Society Limited Vs ACIT (Bombay High Court) Bombay High Court held that since issue already examined during the course of assessment proceedings, re-opening of assessment on same issue amounts to change of opinion. Thus, re-opening based on change of opinion is not sustainable. Accordingly, notice u/s. 148 quashed and set aside. Facts- This Petition challenges notice under Section 148 of the Act dated 31.03.2021 for the assessment year 2014 -15. In this case, an assessment order under Section 143(3) of the Act was passed on 07.12.2016. The impugned notic...