https://www.taxtmi.com/caselaws?id=790727 Reopening of assessment is not justified where the material relied on by the assessing officer was already on record in the original section 143(3) assessment. In such a situation, recorded reasons may amount only to a reason to suspect, not a reason to believe, and the reassessment is vulnerable on the ground of change of opinion. The Court also noted that the assessee's share transaction information was available when the original assessment was completed, so the reopening could not be sustained on the basis of alleged bogus capital gains linked to penny stock transactions. The special leave petition was dismissed. en-us Wed, 15 Apr 2026 00:00:00 +0530 Wed, 29 Apr 2026 11:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790727 Reopening of assessment is not justified where the material relied on by the assessing officer was already on record in the original section 143(3) assessment. In such a situation, recorded reasons may amount only to a reason to suspect, not a reason to believe, and the reassessment is vulnerable on the ground of change of opinion. The Court also noted that the assessee's share transaction information was available when the original assessment was completed, so the reopening could not be sustained on the basis of alleged bogus capital gains linked to penny stock transactions. The special leave petition was dismissed. Case-Laws Income Tax Wed, 15 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790727