Sterling and Wilson (P.) Ltd. v .ACIT (2022)285 Taxman 468 (Bom) ( HC)

S. 147 : Reassessment – Depreciation on goodwill – Change of opinion – Re assessment notice is not valid [ S. 32 , 148 , Art , 226 ]

Reassessment was initiated in case of assessee-company to disallow assessee’s claim of depreciation on goodwill . On writ the Court held that  in original assessment proceedings, assessee had provided details regarding claim of depreciation with supporting evidence and Assessing Officer after considering said evidences, allowed said claim  . On facts, initiation of reassessment was nothing but mere change of opinion . Re assessment notice is quashed . ( AY. 2014 -15))