Reopening of assessment cannot be based on change of opinion

Jamsetjee Jejeebhoy Charity Fund Vs ITO (Exemption) (Bombay High Court) Bombay High Court held that reopening of assessment proceedings on the basis of change of mind/opinion and also on non-application of mind is liable to be quashed and set aside. Accordingly, impugned notices and order quashed. Facts- By the present Petition, the Petitioner has impugned the Notices dated 9th August 2024 and 20th August 2024, which are issued under Section 148A(b) of the Income Tax Act, 1961. The relevant Assessment Year (A.Y.) is 2018-2019. Further, the Petitioner has also impugned the order dated 28th Au...