Reassessment post full and true disclosure results into mere change of opinion hence not sustained

Rao Tradelink Private Limited Vs ITO (Gujarat High Court) Gujarat High Court held that reopening of assessment under section 148 of the Income Tax Act is mere change of opinion since there is no failure on part of assessee as to full and true disclosure. Accordingly, reassessment is liable to be quashed and set aside. Facts- The petitioner, during the year under consideration, was engaged in the business of trading in textile fabrics and made certain purchases from Ruchita Chemicals LLP in the normal course of business and made various payments against such purchases to the said party. The pe...