Reopening inspired from change of opinion is liable to be quashed

BNY Mellon Technology Private Limited Vs ACIT (Madras High Court)

Madras High Court held that reopening of assessment invoking provisions of section 148 of the Income Tax Act inspired from a review and a change of opinion is liable to be quashed and set aside.

Facts- The specific case of the petitioner is that invocation of Section 148 of the Act on 25.03.2021 which is subject matter of challenge was without jurisdiction as the petitioner had filed all the documents that w

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