https://www.taxtmi.com/caselaws?id=762985 Gujarat HC held that reopening assessment under section 147 was invalid as it constituted mere change of opinion. The petitioner had provided complete details of unsecured loans during original assessment including confirmation letters, ITR, and bank statements. The AO was satisfied with these details during regular assessment proceedings. The court ruled that merely because the loan provider incurred losses cannot justify doubting loan genuineness or creditworthiness for reopening assessment. Once an issue is scrutinized during regular assessment, it cannot be reconsidered for reopening unless there is failure to disclose material facts. The notice was issued without jurisdiction and decided in favor of assessee. en-us Tue, 19 Nov 2024 00:00:00 +0530 Wed, 11 Dec 2024 08:15:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762985 Gujarat HC held that reopening assessment under section 147 was invalid as it constituted mere change of opinion. The petitioner had provided complete details of unsecured loans during original assessment including confirmation letters, ITR, and bank statements. The AO was satisfied with these details during regular assessment proceedings. The court ruled that merely because the loan provider incurred losses cannot justify doubting loan genuineness or creditworthiness for reopening assessment. Once an issue is scrutinized during regular assessment, it cannot be reconsidered for reopening unless there is failure to disclose material facts. The notice was issued without jurisdiction and decided in favor of assessee. Case-Laws Income Tax Tue, 19 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762985