Reopening of assessment cannot be based on change of opinion

Clipped from: https://taxguru.in/income-tax/reopening-assessment-based-change-opinion.html

Jamsetjee Jejeebhoy Charity Fund Vs ITO (Exemption) (Bombay High Court)

Bombay High Court held that reopening of assessment proceedings on the basis of change of mind/opinion and also on non-application of mind is liable to be quashed and set aside. Accordingly, impugned notices and order quashed.

Facts- By the present Petition, the Petitioner has impugned the Notices dated 9^th August 2024 and 20^th August 2024, which are issued under Section 148A(b) of the Income Tax Act, 1961. The relevant Assessment Year (A.Y.) is 2018-2019. Further

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