Income Tax Reassessment Reasons amounts to be Mere Change of Opinion without Nexus with Original

The Gujarat High Court ruled that reassessment under the Income Tax Act cannot merely be based on a change of opinion without nexus to original materials. The case highlighted that reassessment reasons must be rooted in tangible material from the original assessment to justify reopening. This decision underscores the importance of maintaining a clear nexus between reassessment grounds and original assessment records to prevent arbitrary reassessment based solely on revised opinions