Tax Reassessment Invalidated: Section 148 Notice Struck Down as Mere Opinion Change Without New Material Evidence

HC ruling on tax reassessment for AY 2014-2015: The court held that the reassessment notice under Section 148 was invalid. The AO's reopening of assessment was deemed a mere change of opinion rather than discovery of new material, as the original assessment was based on search operation materials. The court found that the materials used for reopening were already part of the original assessment proceedings. Consequently, the court set aside the reassessment notice dated 31.03.2021 and the order rejecting objections dated 21.02.2022, effectively allowing the writ petition and invalidating the reassessment proceedings. .....

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