SC Dismisses Reopening Challenge as Mere Change of Opinion Without Fresh Material

DCIT Vs Lupin Limited (Supreme Court of India) The dispute arose from reassessment proceedings initiated for Assessment Year (AY) 2016–17 under the Income Tax Act, 1961. The taxpayer had filed its return of income on 26 November 2016 declaring total income of ₹26,36,01,64,390. The case was selected for scrutiny, during which the Assessing Officer issued multiple notices seeking detailed information, including specific queries on amounts considered disallowable or allowable and on exemptions and deductions claimed under Chapter III and Chapter VI-A. In particular, through queries dated 18 S...