Section 148 reassessment based on mere change of opinion is invalid

Jagannath Promoters & Builders Vs DCIT (Orissa High Court) Conclusion: Reassessment under section 148 was not justified as ‘reason to believe’ that income for the AY in question had escaped assessment was based on a mere ‘change of opinion’. Held: Assessee was a partnership firm. It filed its return for the AY  disclosing a total income of Rs.15,30,110/-. The return was picked up for scrutiny. In response to the notices under Sections 142 (1) and 143 (2), assessee appeared before AO and produced its books of account including cashbook ledger, audit report, balance sheet and profit...