https://www.taxtmi.com/caselaws?id=418317 Where the return was processed under s.143(1) without scrutiny, no opinion is formed by the AO; consequently, the doctrine of "change of opinion" does not bar reopening under s.147, and the AO has wider latitude to reassess. Reopening was upheld because the recorded reasons disclosed tangible information about accommodation-entry/penny-stock manipulation, and the assessee's purchase of shares at a low price followed by abnormal price rise and sale at a high price supplied a live link to the formation of belief that income chargeable to tax had escaped assessment. The writ challenge to reassessment was dismissed. en-us Sat, 05 Feb 2022 00:00:00 +0530 Fri, 02 Jan 2026 10:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418317 Where the return was processed under s.143(1) without scrutiny, no opinion is formed by the AO; consequently, the doctrine of "change of opinion" does not bar reopening under s.147, and the AO has wider latitude to reassess. Reopening was upheld because the recorded reasons disclosed tangible information about accommodation-entry/penny-stock manipulation, and the assessee's purchase of shares at a low price followed by abnormal price rise and sale at a high price supplied a live link to the formation of belief that income chargeable to tax had escaped assessment. The writ challenge to reassessment was dismissed. Case-Laws Income Tax Sat, 05 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418317