Calcutta HC Upheld Income Tax Reassessment as Earlier Order Formed No Opinion

Mark Steels Limited Vs ACIT (Calcutta High Court)

The Calcutta High Court examined a writ petition challenging an order passed under Section 148A(3) of the Income-tax Act, 1961, and the consequential notice issued under Section 148 for the assessment year 2021–22. The challenge was founded on the allegation that the reopening was based on a mere change of opinion, as the issue had already been examined during scrutiny proceedings. The petitioner contended that during the original assessment under Section 143(3), the Assessing Officer had scrutinised alleged cash transactions with

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