Reassessment u/s. 148 quashed as merely based on change of opinion: Madras HC

P.Sundararajan Vs DCIT (Madras High Court)

Madras High Court held that reopening of assessment u/s. 148 of the Income Tax Act merely on the basis of change of opinion does not constitute justification and/or reasons to believe that income chargeable to tax has escaped assessment. Accordingly, appeal allowed and reassessment quashed.

Facts- Assessee is an individual, Director in a company by name S.P.Apparels Ltd. Post completion of scrutiny assessment, assessee received notice dated 25.03.2010 under Section 148 of the Act, to which reply dated 22.04.2010 was

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