Reassessment due to change of opinion is impermissible

Deepak Kapoor Vs PCIT (Delhi High Court) Delhi High Court held that reassessment proceedings cannot be initiated by mere change of opinion of the Assessing Officer regarding the question of the fair market value or whether the amount paid by the assessee to his sisters was deductible from the total consideration. Facts- The petitioner has filed the present petition under Article 226/227 of the Constitution of India challenging the notice under Section 148 of the Income Tax Act, 1961. By the impugned notice, the assessee was called upon to file the return of income for the relevant assessment y...