Reassessment based on change of opinion without any tangible new information unsustainable

Ashraf Chitalwala Vs DCIT (Bombay High Court) Bombay High Court held that the reopening of the assessment order based on change of opinion without surfacing of any tangible new information is unsustainable in law and liable to be set aside. Facts- The Petitioner has assailed notice dated 26th March 2021 issued by the Deputy Commissioner of Income Tax u/s. 148 of The Income Tax Act 1961 seeking to reopen the assessment for the assessment year 2015-16, order dated 24th March 2022 disposing the objections of the Petitioner and the assessment order dated 24th March 2022 u/s. 147 of the Act read wi...