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Reopening of an assessment on mere change of opinion without any tangible material is unsustainable
Case Law Details
- Case Name
- Rallis India Ltd. Vs. ACIT (Bombay High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Bombay High Court
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CASE LAWS DETAILS
DECIDED BY: HIGH COURT OF BOMBAY
IN THE CASE OF: Rallis India Ltd. Vs. ACIT, APPEAL NO: Writ Petition No. 2514 of 2009, DECIDED ON March 4, 2010
RELEVANT PARAGRAPH
We are conscious of the circumstance that in the present case the re-opening of assessment is sought to be effected within a period of four years of the expiry of the relevant assessment year. However, it is now a well settled position of law that a mere change of opinion would not justify the Assessing Officer in seeking a recourse to the powers under Section 147 and 148 and there must be tangible material before...
