2017 (11) TMI 523 - SCH - Income Tax

Validity of reopening of assessment - mere change of opinion - Held that - pecial Leave Petition is dismissed both the ground of delay as well as on merits. HC order confirmed 2017 (1) TMI 816 - BOMBAY HIGH COURT HC has stated that this is a case where the Assessing Officer did apply his mind as evidenced by the query raised to the very issue which is now sought to be raised as the basis for reopening the notice and the Assessing Officer was satisfied with the response to the query during the regular assessment proceedings. Reopening notice is without jurisdiction as it is founded on a mere change of opinion is on facts covered by the decision of this Court in favour of the respondent assessee.