Reassessment Notice for mere change of opinion is impermissible in law

HIGH COURT OF DELHI NTPC Ltd. versus Deputy Commissioner of Income-tax BADAR DURREZ AHMED AND R.V.EASWAR, JJ. W.P.(C) Nos. 14458, 15688, 15693, & 15714 of 2006 Date of pronouncement – 07.03.2013 JUDGMENT Badar Durrez Ahmed, J.  These writ petitions are in respect of notices issued under Section 148 of the Income Tax Act, 1961 seeking to reopen concluded assessments under Section 147 of the said Act. These petitions pertain to the assessment years 1999-2000, 2001-02, 2002-03 and 2003-04. All the impugned Section 148 notices were issued on 03.02.2006. Insofar as the...