Reopening on Share capital issue verified during original assessment not valid

The reasons supplied to the assessee for re­opening of the case relates mainly to Share capital, which is already been investigated by Assessing officer in detail during Original Assessment.  Therefore, The present exercise of issuing the notice under Section 148 of the Act would amount to nothing but a change of opinion, which is not permissible.

The main challenge raised in the writ petition is that the re­assessment proceedings have been initiated after a period of 4 (four) years from the end of

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