Gujarat HC Quashes Income Tax Reopening Notice for Change of Opinion

Hemanshu Ramniklal Shah Vs ITO (Gujarat High Court) In a significant ruling for taxpayers, the Gujarat High Court has quashed a notice issued under Section 148 of the Income-Tax Act, 1961, which sought to reopen the assessment for the Assessment Year 2011-12 for Hemanshu Ramniklal Shah. The court found that the reopening was based on a “change of opinion” by the Assessing Officer and exhibited a lack of application of mind, rather than the discovery of new, undisclosed material facts. The judgment, delivered on May 23, 2025, by a bench comprising Justice Anoop Chitkara, emphasized ...