Mere Change of Opinion not a Ground to Reopen Income Tax Assessment Order u/s 143: Bombay HC

The Bombay High Court has issued a significant ruling concerning the reopening of income tax assessments, asserting that a mere "change of opinion" by tax authorities is not a sufficient ground for reassessment. The court quashed a reassessment order, holding that once an assessment has been completed, it cannot be reopened simply because the assessing officer has a different interpretation of facts or law that were already on record during the original assessment. This decision provides crucial protection to taxpayers against arbitrary reassessments, ensuring finality in tax proceedings and preventing harassment based on a re-evaluation of previously disclosed information.