https://www.taxtmi.com/caselaws?id=344286 The Gujarat HC upheld the AO's decision to reopen assessments for AYs 2011-12 and 2012-13. The assessee challenged the reopening, claiming it was based on change of opinion. The AO had received confidential information from the Principal Director of Income Tax (Investigation), Ahmedabad, following a search operation under Section 132 on an individual who provided accommodation entries. Evidence collected during the search conclusively proved the searched person was engaged in providing bogus accommodation entries, and the assessee was identified as a beneficiary of such entries through various bogus companies. The HC held that the AO possessed tangible material and evidence from the investigation team to prima facie form an opinion that income chargeable to tax had escaped assessment. The court ruled the reopening was not based on change of opinion but on concrete evidence, deciding against the assessee. en-us Fri, 09 Jun 2017 00:00:00 +0530 Tue, 19 May 2026 11:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=344286 The Gujarat HC upheld the AO's decision to reopen assessments for AYs 2011-12 and 2012-13. The assessee challenged the reopening, claiming it was based on change of opinion. The AO had received confidential information from the Principal Director of Income Tax (Investigation), Ahmedabad, following a search operation under Section 132 on an individual who provided accommodation entries. Evidence collected during the search conclusively proved the searched person was engaged in providing bogus accommodation entries, and the assessee was identified as a beneficiary of such entries through various bogus companies. The HC held that the AO possessed tangible material and evidence from the investigation team to prima facie form an opinion that income chargeable to tax had escaped assessment. The court ruled the reopening was not based on change of opinion but on concrete evidence, deciding against the assessee. Case-Laws Income Tax Fri, 09 Jun 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=344286