Re-opening falls within the purview of a ‘Change of Opinion’ and does not fall under 1st Explanation to Section 148 of Income Tax Act: Bombay HC

Recently, the Bombay HC stated that re-opening falls within the purview of a ‘change of opinion’ and does not fall under the 1st Explanation to Section 148 of the Income Tax Act. The bench of Justices K.R. Shriram and Neela Gokhale was dealing with the petition challenging the notice issued under Section 148 of the

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