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Reopening under s.147 based on alleged cash purchases reflected in TAS was challenged as an impermissible change of opinion after the AO had earlier dropped inquiry for want of evidence. The court held that "opinion" requires formation on available material; mere availability of transaction entries without corroborative data linking the assessee to the alleged counterparty did not amount to an opinion, particularly when the assessee denied any relationship, making verification impossible. Since the impugned s.148 notice relied on new, tangible material establishing the linkage, no jurisdictional error was shown and the reopening was upheld. - HC
Reopening under s.147 based on alleged cash purchases reflected in TAS was challenged as an impermissible change of opinion after the AO had earlier dropped inquiry for want of evidence. The court held that "opinion" requires formation on available material; mere availability of transaction entries without corroborative data linking the assessee to the alleged counterparty did not amount to an opinion, particularly when the assessee denied any relationship, making verification impossible. Since the impugned s.148 notice relied on new, tangible material establishing the linkage, no jurisdictional error was shown and the reopening was upheld. - HC
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