THE HONOURABLE MR. MANINDRA MOHAN SHRIVASTAVA, CHIEF JUSTICE AND THE HONOURABLE MR.JUSTICE SUNDER MOHAN W.A.No.2391 of 2025 and C.M.P.No.18150 of 2025 The Assistant Commissioner of Income Tax Corp Circle – 2(1) Chennai

5^th Floor, Chennai-600 017.

Appellant Vs EIH Associated Hotels Limited rep. by Power of Attorney Holder, J.Suresh

1/24, GST Road, Meenambakkam, Chennai-600 017 Respondent P RAYER: Appeal filed under Clause 15 of the Letters Patent against the order dated 19.7.2022 passed by the learned Single Judge in W.P.No.25229 of 2019.

For Appellant: Mr.A.P.Srinivas Babu Senior Standing Counsel For Respondent: Mr.Suhrith Parthasarathy JUDGMENT (Delivered by the Hon'ble Chief Justice)

Heard on admission.

2. Learned counsel for the Revenue would submit that the order passed by the learned Single Judge suffers from material illegality as the learned Single Judge fell in error of law in classifying disclosure of new material as change of opinion. Referring to the contents of paragraph 2.4 of the notice dated 4.6.2019 for reopening assessmen