Reopening of assessment merely based on change of opinion is unsustainable

Gandhibag Sahakari Bank Limited Vs DCIT (Bombay High Court)

Bombay High Court held that re-opening of assessment under section 148 of the Income Tax Act, without indicating basis for having a reason to belief that income has escaped assessment, merely based on change of opinion is unsustainable in law and liable to be quashed.

Facts- The challenge raised in the present writ petition is to the notice dated 31.03.2021 issued by the Assistant Commissioner of Income Tax under

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