A change of opinion cannot be the basis of reopening the completed assessment

JRS Pharma and Gujarat Microwax Private Limited Vs DCIT (Gujarat High Court)

Question of law: whether the revenue is justified in reopening the assessment for the year under consideration?

Writ application filed before the Hon’ble HC of Gujrat challenging notice u/s 148 of the Income Tax Act, 1961 for reopening the assessment for AY 2013-14.

During the FY 2012-13, the assessee company had entered into various international transactions

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