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    <title>2025 (9) TMI 524 - GUJARAT HIGH COURT</title>
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    <description>HC held that reopening assessment under s.147 was invalid where the taxpayer had already disclosed the same amount as long-term capital gains during regular assessment and no new tangible facts linked to escapement of income were shown. The AO&#039;s action amounted to a mere change of opinion in treating the gains as business income, and objections were disposed of only after the assessment order was digitally signed, undermining jurisdiction. Reopening was quashed and decision rendered for the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=778035</link>
      <description>HC held that reopening assessment under s.147 was invalid where the taxpayer had already disclosed the same amount as long-term capital gains during regular assessment and no new tangible facts linked to escapement of income were shown. The AO&#039;s action amounted to a mere change of opinion in treating the gains as business income, and objections were disposed of only after the assessment order was digitally signed, undermining jurisdiction. Reopening was quashed and decision rendered for the assessee.</description>
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