Re-opening of assessment in absence of any new tangible material is unsustainable

Clear Media (India) Private Limited, Vs DCIT (Bombay High Court) Bombay High Court held that in absence of any receipt of new information or reference to any new material on record, it can be concluded that re-opening of assessment is merely because of change of opinion and the same is unsustainable in law. Facts- In this petition, the petitioner challenges the notice, dated 30th March 2021 issued by respondent No.1 under section 148 of the Income Tax Act, 1961 (‘the Act’) proposing to reopen the assessment for the assessment year 2016-17 on the ground that the income exigible to tax for t...