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Mira Bhavin Mehta v. ITO: The Bombay High Court in the case W.P.(C) 3246 of 2022 has held that the change of opinion does not constitute justification for assuming that income chargeable to tax has escaped assessment and that the AO cannot initiate the reopening of the assessment. The bench further observed that the AO in the assessment order has noted that the issue of investment in immovable property and capital gain or income on sale of property was considered under limited scrutiny and in view of the material on record, no addition on the issue is made. The information relied upon while issuing notice under Section 148A(b) relates to the flat and the gain arising on the transfer of the said flat is a short-term capital gain.