https://www.taxtmi.com/caselaws?id=460327 The Gujarat HC ruled in favor of the assessee, holding that the reopening of assessment under Section 148 was invalid. The court found that the AO mechanically recorded reasons without applying mind, incorrectly stating the assessment was processed under Section 143(1) when it was actually completed under Section 143(3). Since the original assessment order was passed with full knowledge of transaction details through M/s. Divya Commodities on NMCE platform, reopening based on the same details constituted an impermissible change of opinion. The notice under Section 148 and order disposing objections were deemed illegal. en-us Wed, 28 Feb 2024 00:00:00 +0530 Mon, 03 Mar 2025 15:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460327 The Gujarat HC ruled in favor of the assessee, holding that the reopening of assessment under Section 148 was invalid. The court found that the AO mechanically recorded reasons without applying mind, incorrectly stating the assessment was processed under Section 143(1) when it was actually completed under Section 143(3). Since the original assessment order was passed with full knowledge of transaction details through M/s. Divya Commodities on NMCE platform, reopening based on the same details constituted an impermissible change of opinion. The notice under Section 148 and order disposing objections were deemed illegal. Case-Laws Income Tax Wed, 28 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460327