Court Affirms Reopening of Tax Assessment u/s 147 for Undisclosed Capital Gains from Penny Stocks Transactions.

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....Reopening of assessment u/s 147 - undisclosed LTCG - when the information was specific with regard to transactions of penny stock entered into by the assessee, and the AO had applied his independent mind to the information and upon due satisfaction, led to form an opinion that, the amount of claim of LTCG claimed by the assessee is chargeable to tax has escaped assessment, which facts suggests that, there is live link between the material which suggested escapement of income and information of belief. Under the circumstances, we are satisfied that, there was enough material before the AO to initiate proceedings under Section 147 of the Act. - HC....