Change of opinion: Whether permissible under the new provisions of reassessment?

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The Finance Act, 2021 overhauled the then-existing reassessment provisions under the Income-tax Act. Earlier, the reassessment provisions required the Assessing Officer to form an “independent belief” based on the “new tangible material”. Now, the reassessment provisions have been made information centric. The Assessing Officer is required to possess the information that suggests that the income chargeable to tax has escaped assessment. For that matter, what constitutes information has also been defined under the Act. When the reopening has now been made permissible on the possession of the defined information, the question is whether a change of opinion based on such information can result in a valid reopening. This Podcast seeks to discuss this crucial aspect of the new reassessment provisions.
Link: Change of opinion: Whether permissible under the new provisions of reassessment? | Lakshmikumaran & Sridharan Attorneys (lakshmisri.com)

Source: An article published on the LKS website in July 2023
Authors: Neha Sharma
Voice: Arpit Mehra and Kanishka Sihare