Validity of reopening assessment u/s 147 challenged. Profit...

Validity of reopening assessment u/s 147 challenged. Profit earned by trading in shares treated as unexplained credit u/s 68. Held: Petitioner disclosed all material facts including derivatives transactions in books during regular assessment proceedings. Assessing Officer passed order u/s 143(3) assessing total income. Despite profit from transactions being offered to tax in return, reopening initiated based on information received. However, Assessing Officer failed to correlate information with records and material already scrutinized during regular assessment. Petitioner provided all information, disclosing material facts fully. Reopening notice without jurisdiction, contrary to provisions, as no fresh tangible material for reasonable belief of escaped income. Mere change of opinion on profit already offered to tax. Decided in favor of assessee. Impugned notice quashed and set aside.

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