Assessing Officer’s ‘Change of Mind’ Not Valid Ground for Reopening Assessment : Madras HC

The Madras High Court has ruled that an "Assessing Officer's change of mind is not a valid ground for reopening assessment." This significant judgment provides crucial protection for taxpayers against arbitrary reassessments. The court emphasized that the power to reopen an assessment can only be exercised based on "tangible material" or new information that indicates escapement of income, and not merely because an Assessing Officer has a "change of opinion" on facts already considered. This reinforces the finality of assessments.