2009 (3) TMI 28 - BOMBAY HIGH COURT

Validity of notice issued u/s 148 to reopen the assessment – AO rejecting the objections raised by the petitioner regarding the reopening of assessment - assessment is sought to be reopened on the basis of the material based on which a final decision has already been taken, and therefore, the reopening of the assessment based on the very same materials to take a contrary view constitutes reopening on account of change of opinion which is not permissible u/s 147 - notice is quashed and set aside