The High Court of Bombay has quashed reassessment order and held

The High Court of Bombay has quashed reassessment order and held

The High Court of Bombay has quashed reassessment order and held that between the date of the order of assessment sought to be reopened and the date of forming of opinion by the Assessing Officer, nothing new has happened. Neither is there any new information received nor is a reference made to any new material on record. The Assessing Officer simply has accorded a fresh consideration and come to a conclusion that the assessee ought to have claimed benefit of deduction under section 35ABB which would have resulted in reducing the allowance under section 32. In the absence of any tangible material, this case is nothing but a case of change of opinion and thus does not satisfy the jurisdictional foundation under section 147 of the Act. (Clear Media (India) Pvt Ltd vs DCIT)



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