It is not permissible to reopen based on change of opinions: HC

Samet Estates Pvt. Ltd. Vs CIT (Bombay High Court) It is Petitioner’s case that the same issue which is mentioned in the reasons for reopening was a subject matter of consideration during the assessment proceedings and the assessment order dated 20th December, 2010 in fact even discussed this item. Therefore, reopening is based on change of opinion which is not permissible. Third point of challenge to notice is the very subject matter of reasons for reopening was a subject of revision proceedings under Section 263 of the Act and Commissioner of Income Tax had issued a notice dated 21st Janua...