Bombay High Court reassessment initiated just on the basis of change of opinion

INCOME TAX : Where Assessing Officer issued notice under section 148 on ground that income chargeable to tax had escaped assessment doubting genuineness of transaction of issue of shares by assessee-company to its existing shareholders, since said issue was subject matter of regular assessment proceedings under section 143(3), it was case of change of opinion by Assessing Officer, therefore, impugned notice was to be quashed

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