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Bombay High Court Quashes Reopening Notice Under Section 148 of Income Tax Act for Lack of Fresh Material — Mere Change of Opinion Invalid. Reassessment Based on Same Commencement Certificate Date Already Considered in Original Assessment Under Section 143(3) Cannot Be Sustained.

The petitioner, M/s. Mistry Lalji Narsi Development Corporation, a partnership firm engaged in development and construction, challenged a notice issue...