Upal Developers (P.) Ltd. v. Dy.CIT (2022) 285 Taxman 23 (Bom)(HC)

S.147: Reassessment – After the expiry of four years – Change of opinion -Rental income from shops – Income from house property -Income from business – Income from other sources -Reassessment notice was quashed [ S. 22, 28(i), 56 ,148 Art , 226 ]

 Allowing the petition the Court held that the details were available not only in return of income, profit and loss account and balance sheet filed by assasessee but all these issues had been raised and considered in original assessment order. On facts, reassessment was a mere change of opinion hence the notice was  quashed – Held, yes ( AY. 2012 -13 )