Q. What is the doctrine of change of opinion in reassessment proceedings?

The doctrine of change of opinion prohibits reassessment where the Assessing Officer merely re-examines material already considered during the original assessment, without any fresh tangible material.

Q. Can reassessment be initiated after section 148A on a change of opinion?ers.

No. Courts have held that section 148A is procedural and does not cure a jurisdictional defect arising from reassessment based on change of opinion.

Q. Does absence of discussion in the assessment order mean no opinion was formed?

No. Courts recognise that an opinion can be deemed to have been formed where queries were raised and replies were furnished, even if the assessment order is silent.

section 148a income tax act

Income Tax
Change of Opinion: Why Reassessment Fails
Reassessment fails when based on change of opinion. Learn how courts treat such notices as void despite section 148A and lack of fresh tangible material.
Read More Change of Opinion: Why Reassessment Fails

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section 148a income tax act

Change of Opinion: Why Reassessment Fails

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