The issues raised in the reasons for reopening were subject matter of consideration before the Assessing Officer. On writ the Court held that  when primary facts necessary for assessment are fully and truly disclosed, the Assessing Officer is not entitled to change of opinion to commence the proceedings for reassessment. The court quashed and set aside the notice and the order.  Court also observed that the Assessing Officer has not dealt with any of the submissions and referred 68 case laws without stating how the case laws are applicable to the facts of the petitioner.  [WP (L) No. 6861/2022 dt. 9-3-2022 (AY.  2015-16)]

Hitech Corporation Ltd. (Formerly known as Hitech Plast Ltd.) v.  ACIT (Bom.)(HC)(UR)