https://www.taxtmi.com/caselaws?id=793214 A return processed only under section 143(1) does not bar reopening under section 147, because there is no prior assessment on merits and therefore no question of change of opinion; on the facts stated, the reopening was supported by recorded reasons and Investigation Wing material, so the reassessment quashing was set aside for fresh consideration. As to alleged bogus long-term capital gains from penny stock transactions, documentary evidence of purchase, demat holding, sale through a registered broker, banking channels and securities transaction tax was found sufficient for the later years, while the Revenue lacked cogent material linking the assessee to price rigging, entry operators or accommodation entries; mere suspicion and general reports were held insufficient, and the additions under sections 68 and 69C were deleted. en-us Tue, 24 Mar 2026 00:00:00 +0530 Thu, 11 Jun 2026 08:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793214 A return processed only under section 143(1) does not bar reopening under section 147, because there is no prior assessment on merits and therefore no question of change of opinion; on the facts stated, the reopening was supported by recorded reasons and Investigation Wing material, so the reassessment quashing was set aside for fresh consideration. As to alleged bogus long-term capital gains from penny stock transactions, documentary evidence of purchase, demat holding, sale through a registered broker, banking channels and securities transaction tax was found sufficient for the later years, while the Revenue lacked cogent material linking the assessee to price rigging, entry operators or accommodation entries; mere suspicion and general reports were held insufficient, and the additions under sections 68 and 69C were deleted. Case-Laws Income Tax Tue, 24 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793214