Allowing the petition the Court held that the AO has passed the original assessment order by calling the information and getting the confirmation from the parties .The AO cannot reopen the assessment on the ground that further verification and investigation was required. On the basis of the very same material, the assessment could not be reopened on some change of opinion. In the facts and circumstances of the case, the notice of reassessment was not valid. (AY. 2013-14)
Jarun Pharmaceuticals Pvt. Ltd. v. ITO (2019) 416 ITR 249 (Guj)(HC)
S. 147 : Reassessment –With in four years- Change of opinion- Details were submitted in the original assessment proceedings – Reassessment for purpose of verification and investigation is held to be not valid .[ S.148 ]