High Court Invalidates Assessment Reopening u/s 147 Due to AO's Change of Opinion on Unsecured Loan.

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....Reopening of assessment u/s 147 - change of opinion - It was not as if the AO did not address his mind to various facets of the ROI. Clearly, the route chosen by the respondent/revenue was not the correct course of action. During scrutiny assessment, as noticed above, a specific query was raised vis-à-vis unsecured loan which was answered; whereupon it was closed, presumably on ground that it was indeed a genuine transaction as claimed by the petitioner. - Notice issued u/s 148 quashed - HC....