Mere change of opinion: Bombay HC Quashes Tax Section 148 Reopening notice 

Genesys International Corp. Ltd. Vs ACIT (Bombay High Court)

Bombay High Court has quashed a Section 148 notice issued by the Income-tax Department to Genesys International Corp. Ltd. for Assessment Year 2015-16, ruling that the reopening of the assessment was based on a “mere change of opinion” and that the taxpayer had made complete disclosures during the original assessment.

Genesys International Corp. Ltd. had filed its income tax return for AY 2015-16 on November 30, 2015. The original assessment was completed under Section 143(3) on Decembe

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