Reassessment u/s. 148 based on mere change of opinion impermissible: Gujarat HC

Hareshkumar Bhupatbhai Panchani Vs ITO (Gujarat High Court) Gujarat High Court held that reopening of assessment under section 148 of the Income Tax Act on mere change of opinion is not permissible in law. Accordingly, petition allowed and reassessment notice quashed. Facts- The petitioner sold an immovable property along with other co-owners for a consideration of Rs.12,35,90,464/-, wherein share of the petitioner was for Rs.02,83,54,388/-. The petitioner having made specific investment, claimed deduction of Rs.01,33,02,123/- u/s. 54F of the Act. Details of such investment are reflected in th...