https://www.taxtmi.com/caselaws?id=783249 ITAT Pune held the reassessment notice u/s 148 to be invalid as it was based on a mere change of opinion. The AO had earlier, on the same material and after full enquiry, accepted the assessee's claim of LTCG and dropped the proceedings u/s 143(3) r.w.s. 147. Issuance of a fresh notice without any new tangible material or independent enquiry was held impermissible. Consequently, the reassessment proceedings and additions made u/s 69A r.w.s. 115BBE were quashed. On merits, ITAT further held that the assessee satisfied all conditions of s.10(38), and in view of SEBI's final report exonerating the concerned scrip from price rigging, the LTCG was genuine. The denial of exemption and related additions were deleted. en-us Fri, 28 Nov 2025 00:00:00 +0530 Wed, 10 Dec 2025 11:27:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783249 ITAT Pune held the reassessment notice u/s 148 to be invalid as it was based on a mere change of opinion. The AO had earlier, on the same material and after full enquiry, accepted the assessee's claim of LTCG and dropped the proceedings u/s 143(3) r.w.s. 147. Issuance of a fresh notice without any new tangible material or independent enquiry was held impermissible. Consequently, the reassessment proceedings and additions made u/s 69A r.w.s. 115BBE were quashed. On merits, ITAT further held that the assessee satisfied all conditions of s.10(38), and in view of SEBI's final report exonerating the concerned scrip from price rigging, the LTCG was genuine. The denial of exemption and related additions were deleted. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783249