No assessment can be reopened merely on the basis of change of opinion

Knight Riders Sports Pvt. Ltd. Vs ACIT (Bombay High Court) Bombay High Court held that no assessment can be reopened merely on the basis of change of opinion. Accordingly, initiation of re-assessment proceedings under section 148 of the Income Tax Act is unsustainable in law. Facts- Petitioner carried on the business of operating and running a team in the Indian Premier League, i.e., Kolkata Knight Riders. During the years Petitioner paid a sum of Rs.3,04,85,970/- as management fees towards consultancy and team management fees. A sum of Rs. 1.90 crores was paid as consultancy fees to one Insig...