https://www.taxtmi.com/caselaws?id=790045 Reopening under section 147 cannot stand where it is based on the same survey material, partner statement, investigation report and penny stock loss details already specifically called for and examined in the original scrutiny assessment under section 143(3). The record showed that notices, replies, demat statements, broker ledgers, contract notes, bank statements, volatility charts and the survey statement were all before the AO at the time of the original assessment, so the later action amounted to a mere review of a concluded assessment rather than reopening on fresh tangible material. The notice under section 148 and the reassessment were therefore invalid and quashed. en-us Wed, 25 Mar 2026 00:00:00 +0530 Sat, 18 Apr 2026 08:22:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790045 Reopening under section 147 cannot stand where it is based on the same survey material, partner statement, investigation report and penny stock loss details already specifically called for and examined in the original scrutiny assessment under section 143(3). The record showed that notices, replies, demat statements, broker ledgers, contract notes, bank statements, volatility charts and the survey statement were all before the AO at the time of the original assessment, so the later action amounted to a mere review of a concluded assessment rather than reopening on fresh tangible material. The notice under section 148 and the reassessment were therefore invalid and quashed. Case-Laws Income Tax Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790045