Without fresh tangible material reassessment of earlier Assessment is unsustainable

Pushpa Nahata Vs ITO (Bombay High Court) Bombay High Court held that in absence of any fresh tangible material and simply attempting to re-visit and reconsider the decision which was rendered in earlier regular assessment proceedings is nothing but a change of opinion and hence reopening unsustainable. Facts- The petitioner challenges the notice under section 148 of the Income Tax Act, 1961 (‘the Act’) dated 30th March 2022 as also the order of assessment dated 22nd March 2022 passed under section 147 read with section 144/144B of the Act as bad and illegal and in excess of jurisdiction. O...