Reassessment u/s 148 Quashed for Change of Opinion: Tripura HC

Abhijit Paul Vs Union of India (Tripura High Court) Tripura High Court held that reopening of assessment u/s. 148 of the Income Tax Act results into mere change of opinion as reopening is based on the same material as that of original assessment order. Accordingly, reopening of assessment resulting into change of opinion is bad-in-law and hence liable to be quashed. Facts- Vide the present petition, the Petitioner has sought quashing of notice u/s. 148 of the Income Tax Act, 1961 issued by the Deputy Commissioner of Income Tax for the assessment year 2014-2015 and the order dated 21.02.2022 re...