HC quashes Notice for re-assessment based on change of opinion

Bharti Infratel Limited Vs DCIT (Delhi High Court) Conclusion: Notice for re-assessment issued under Section 148 against assessee-company was quashed as assessee had made full and true disclosure of material facts; nothing was concealed, withheld and left to be factually discovered in the form of ‘material’ mentioned in detail in accounts and other evidence and moreover, it would be a case of change of opinion as the facts were within the knowledge of the AO when he had passed the original assessment order. Held: In the present case, assessee-company had challenged the legality and validit...