Change of opinion cannot be basis for reassessment proceedings u/s. 148: Madras HC

CIT Vs Hyundai Motor India Ltd (Madras High Court) Madras High Court held that reassessment proceedings under section 148 of the Income Tax Act initiated on the basis of change of opinion is invalid. Accordingly, appeal of revenue dismissed and substantial questions of law is answered in favour of assessee. Facts- Assessee, which is a motor car manufacturing company. Post scrutiny assessment, Assessing Officer issued notice dated 17.3.2009 under Section 148 of the Act. After hearing assessee and after rejecting the objections filed to the validity of reopening, the assessment u/s. 143(3) read ...