Triggering of re-assessment proceedings on matter for which AO had already formed an opinion is untenable

Basic Clothing Private Limited Vs ITO (Delhi High Court) Delhi High Court held that it is settled legal position that re-assessment proceedings under section 148 of the Income Tax Act cannot be triggered on the aspects which AO has already formed an opinion. Accordingly, notice issued u/s 148 set aside. Facts- Vide the present writ petition, the petitioner/assessee claims that there has been a change of opinion inasmuch as the allegations based on which the reassessment proceedings having been commenced were the subject matters of the assessment order dated 31.03.2022, passed u/s. 147 read wit...