Reopening of assessment without fresh tangible material not sustainable: Bombay HC

Lupin Limited Vs DCIT (Bombay High Court) Bombay High Court held that reopening of assessment without fresh tangible material based upon mere change of opinion is unsustainable in law. Accordingly, notice and consequential orders set aside. Facts- The Petitioner challenges the notice dated 31 March 2021 issued by the first Respondent under Section 148 of the Income Tax Act, 1961 seeking to reopen the assessment for A.Y. 2016-17 together with consequential notices and orders and order dated 30 November 2021 rejecting the Petitioner’s objections to the reopening of the assessment. Conclusion- ...