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of The ITAT addressed reassessment proceedings under Section 148, finding the Assessing Officer's (AO) reasons to believe were valid based on information from the DIT(System). The tribunal rejected the assessee's argument of mere 'change of opinion' and upheld the approval under Section 151 as independent and substantive. Regarding share transfer, the ITAT ruled against the AO's 'look through approach' and invalidated the recharacterization of share sale as asset sale. The tribunal specifically held that Section 50CA could not be retrospectively applied for Assessment Year 2015-16, directing deletion of short-term capital gains additions. The appeal grounds relating to reassessment and valuation were partially allowed, with grounds 3-7 dismissed and grounds 12-18 allowed.
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