In this case assessment under section 143(3) of the said Act has been completed and assessment order had been passed. The reasons recorded for reopening itself discloses that it is nothing but change of opinion of the AO proposing to reopen. The court quashed and set aside the impugned notice and the  order. (WP  (L) No. 3403/2022 dt.16-3-2022.)(AY.  2017-18)

John Cockerill India Limited v. UOI (Bom.)(HC) (UR)