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)

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