Reassessment only on account of ‘change of opinion’ is liable to be struck down

Rampal Samdani Vs Union of India (Rajasthan High Court) Rajasthan High Court held that reassessment resorted only on account of ‘Change of opinion’ of AO and without there being any fresh tangible evidence for reopening the assessment proceedings is liable to be struck down. Facts- The petitioner did not furnish his return of income for A.Y. 2013-14 for the reason that he was having income lower than the basic exemption limit prescribed under the Income Tax Act and Rules. A notice dated 08.04.2016 was issued by the ITO proposing to initiate assessment proceedings u/s. 147 of the Income Tax...