https://www.taxtmi.com/caselaws?id=784049 Reopening under s.147 on alleged cash purchases reflected in TAS was challenged as a barred "change of opinion" after the AO had earlier dropped the query for lack of evidence. The HC held that mere availability of transaction entries, without contemporaneous material linking the assessee to the third-party group and where the assessee denied any relationship, did not amount to a formed opinion in scrutiny. Since the s.148 notice was founded on subsequent, new and tangible material establishing a relationship that was absent during s.142(1) proceedings, no jurisdictional error was shown and the challenge on change-of-opinion failed. The question of AO competence post s.151A scheme was noted as jurisdictional but left for detailed consideration. en-us Wed, 24 Dec 2025 00:00:00 +0530 Sat, 27 Dec 2025 08:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784049 Reopening under s.147 on alleged cash purchases reflected in TAS was challenged as a barred "change of opinion" after the AO had earlier dropped the query for lack of evidence. The HC held that mere availability of transaction entries, without contemporaneous material linking the assessee to the third-party group and where the assessee denied any relationship, did not amount to a formed opinion in scrutiny. Since the s.148 notice was founded on subsequent, new and tangible material establishing a relationship that was absent during s.142(1) proceedings, no jurisdictional error was shown and the challenge on change-of-opinion failed. The question of AO competence post s.151A scheme was noted as jurisdictional but left for detailed consideration. Case-Laws Income Tax Wed, 24 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784049