High Court Rules Reassessment Notice under Section 148 Cannot Be Issued on Mere Change of Opinion:

High Court Rules Reassessment Notice under Section 148 Cannot Be Issued on Mere Change of Opinion

The Gujarat High Court has held that where an assessment has been completed under Section 143(3) it cannot be reopened merely on a change of opinion.

High Court quashes reopening proceedings for 2012-13

authorSaimadateJul 17, 2026
Last update on Jul 17, 2026
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High Court Rules Reassessment Notice under Section 148 Cannot Be Issued on Mere Change of Opinion

The Gujarat High Court has held that where an assessment has been completed under Section 143(3) it cannot be reopened merely on a change of opinion.

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Saima

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Saima is a Law graduate with a passion for research and content writing. She writes for Finance, Taxation and Legal Updates at Studycafe.in, simplifying complex legal decisions by the ITAT, High Court, AAR and GSTAT into uncomplicated and clear explanations.
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Delhi, Delhi, India
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