Reopening unsustainable as post assessment there was no change in law and no new material came on record

D.K. Realty India Private Limited Vs ACIT (Bombay High Court) Bombay High Court held that as between the date of the orders of assessment sought to be reopened and the date of forming of opinion by the Income-tax Officer nothing new has happened i.e. there is no change in law, no new material came on record and no new information has been received. Hence, reopening proceedings was just change of opinion accordingly the same is unsustainable in law. Facts- The petitioner challenges the notice dated 30th March 2021 issued under section 148 of the Income Tax Act, 1961 (‘the Act’) which sought...