Reopening of an assessment on mere change of opinion without any tangible material is unsustainable

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...