https://www.taxtmi.com/caselaws?id=757971 Gujarat HC held that reopening of assessment under Section 148 was invalid where AO had already examined unsecured loans during original assessment proceedings under Section 143(3). The court found no income had escaped assessment as the AO had specifically called for and considered unsecured loan details during regular assessment. The difference between book amounts and AO's addition constituted mere change of opinion, insufficient for reopening. Additionally, since the original addition was successfully challenged before Commissioner (Appeals), the issue had merged into appellate order, precluding reassessment on same grounds. Assessee's appeal was allowed. en-us Tue, 13 Aug 2024 00:00:00 +0530 Thu, 05 Sep 2024 07:50:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757971 Gujarat HC held that reopening of assessment under Section 148 was invalid where AO had already examined unsecured loans during original assessment proceedings under Section 143(3). The court found no income had escaped assessment as the AO had specifically called for and considered unsecured loan details during regular assessment. The difference between book amounts and AO's addition constituted mere change of opinion, insufficient for reopening. Additionally, since the original addition was successfully challenged before Commissioner (Appeals), the issue had merged into appellate order, precluding reassessment on same grounds. Assessee's appeal was allowed. Case-Laws Income Tax Tue, 13 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757971