Reopening of assessment u/s. 148 on mere change of opinion is invalid: ITAT Chennai

J Ray McDermott Engineering Services Pvt. Ltd. Vs DCIT (ITAT Chennai) ITAT Chennai held that reopening of assessment u/s. 148 of the Income Tax Act on mere change of opinion without satisfying necessary ingredients for initiating reassessment is invalid and liable to be quashed. Accordingly, reassessment set aside. Facts- The assessee is a private limited company engaged in the business of providing design and drawing services for engineering industry. The assessment of the assessee was reopened and notice u/s.148 of the Act was issued on 28.02.2019. The reason for issuance of notice for reope...