Court Quashes Income Assessment Reopening u/s 147; No New Material or Direct Link to SEBI Order Found.

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....Reopening of assessment u/s 147 - Reopening based on the order of SEBI in cases of reversal trades and accommodation entries - As evidenced that there is no live link or nexus with the alleged orders passed by SEBI as alleged by the Respondent. Besides the Respondent has failed to aver the particulars of the information available which has led to the belief that income has escaped assessment. There appears no new tangible material available on record to conclude that income had escaped assessment - It is clearly a ‘change of opinion’ - Notice quashed and set aside - HC....