Assessment Re-Opened By Dept. Based On 'Change Of Opinion'; Himachal Pradesh High Court Quashes Reassessment

The Himachal Pradesh High Court ruled that reassessment cannot merely be based on a change of opinion unless there is fresh tangible material. The case involved the reopening of assessment by the Income Tax Department based solely on a revised interpretation of facts. The court emphasized that reassessment must be backed by new material that wasn't available during the original assessment. It held that mere change in opinion by tax authorities is insufficient grounds for reassessment under the Income Tax Act. This decision underscores the requirement for substantial new evidence to justify reopening assessments beyond initial findings.