Vodafone Idea Ltd ( 2022) 285 Taxman 381 ( Bom)( HC)

S.147: Reassessment – After the expiry of four years – Change of opinion- Minimum alternative tax-No whisper as to was not disclosed – Reassessment notice was quashed [S. 115JB, 148 , Art, 226 ]

Allowing the petition the Court held that where assessee had truly and fully disclosed all material facts necessary  for purpose of assessment and they were carefully by Assessing Officer and in reason for reopening there was not even a whisper as to what was not disclosed , the case was change of opinion . The reassessment notice was quashed . ( AY. 2013 -14 )