Reassessment u/s. 148 quashed as initiated inspite of full and true material disclosure: Bombay HC

Bharat Petroleum Corporation Ltd. Vs ACIT (Bombay High Court) Bombay High Court held that reopening of assessment under section 148 of the Income Tax Act merely on the basis of change of opinion is not sustainable in law. Also, held that reassessment proceedings are initiated after four years without failure to disclose fully and truly all the material facts hence the same cannot be sustained. Facts- The Petitioner is a Company engaged in the business of refining of crude oil and marketing of petroleum and petrochemical products and lubricants and is a regular Assessee under the IT Act. Vide t...