https://www.taxtmi.com/caselaws?id=445147 Gujarat HC held that reopening of assessment u/s 147 was invalid where assessee had provided plausible explanation for large cash deposits through summons u/s 131(1A), submitted reconciliation statements, and made complete disclosure in original assessment. The court found revenue's action constituted mere change of opinion without proper reason to believe, lacking jurisdictional basis. Citing Kelvinator of India precedent requiring link between reason and belief formation, the court ruled in favor of assessee against reopening. en-us Tue, 12 Sep 2023 00:00:00 +0530 Thu, 19 Feb 2026 12:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445147 Gujarat HC held that reopening of assessment u/s 147 was invalid where assessee had provided plausible explanation for large cash deposits through summons u/s 131(1A), submitted reconciliation statements, and made complete disclosure in original assessment. The court found revenue's action constituted mere change of opinion without proper reason to believe, lacking jurisdictional basis. Citing Kelvinator of India precedent requiring link between reason and belief formation, the court ruled in favor of assessee against reopening. Case-Laws Income Tax Tue, 12 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445147