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    <title>2025 (1) TMI 766 - GUJARAT HIGH COURT</title>
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    <description>Gujarat HC quashed reassessment notice for AY 2015-16 issued based on Project Falcon information regarding alleged non-genuine trading in stock options. Court held AO mechanically reopened assessment without independent application of mind, relying solely on borrowed satisfaction from external sources. Since assessee had disclosed profits from futures and options which were accepted during original assessment, reopening was deemed change of opinion rather than escapement of income. AO failed to form independent opinion after considering material on record, making reassessment invalid.</description>
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      <description>Gujarat HC quashed reassessment notice for AY 2015-16 issued based on Project Falcon information regarding alleged non-genuine trading in stock options. Court held AO mechanically reopened assessment without independent application of mind, relying solely on borrowed satisfaction from external sources. Since assessee had disclosed profits from futures and options which were accepted during original assessment, reopening was deemed change of opinion rather than escapement of income. AO failed to form independent opinion after considering material on record, making reassessment invalid.</description>
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