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 filed. Thereafter, assessment order...