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 Section 148 of the Income Tax Act, 1961. By the said notice it was proposed to re-assess the income/loss of the petitioner ...