Reopening based on material available during assessment proceedings not permissible: Bombay HC

Shri Saibaba Sansthan Trust (Shirdi) Vs Union of India (Bombay High Court)

Bombay High Court held that reopening of assessment u/s. 147 in absence of any fresh material, based on material already available during assessment proceedings, tantamount to mere change of opinion and the same is not permissible in law.

Facts- The petitioner is a Public Trust deemed to be constituted and governed under the State Legislation namely under the provisions of the “Shri Saibaba Sansthan Trust (Shirdi) Act, 2004”. Despite past assessments, the petitioner was issued a s

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