Gujarat HC Quashes Section 148 Reopening Notice Over Incorrect Facts & Change of Opinion

Kapadia Money Changers Pvt. Ltd Vs ACIT (Gujarat High Court) Gujarat High Court has quashed a notice issued by the Assistant Commissioner of Income Tax (ACIT) seeking to reopen the assessment of Kapadia Money Changers Pvt. Ltd. for the Assessment Year (AY) 2013-14. The court found that the Assessing Officer (AO) displayed a “total non-application of mind” while rejecting the assessee’s objections and that the reopening was based on a “mere change of opinion” and incorrect facts. The petitioner, an authorized dealer of foreign exchange, challenged the Section 148 n...