Reopening of assessment on the basis of change of opinion is untenable

Bharat Amratlal Shah Vs ITO (Bombay High Court)

Bombay High Court held that reopening of assessment on the basis of change of opinion without reasons to indicate failure on the part of the petitioner to disclose truly and fully all the material facts is untenable in law.

Facts- The Petitioner filed return of income and computation of income of the for A.Y. 2015-16 on 4th January 2016. The Petitioner computed Rs.6.82 crores as long-term capital gain (LTCG) after deducting t

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