Tax Reassessment Notice Invalidated Due to Lack of Evidence, Court Rules Change of Opinion Not Sufficient for Action.

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....Reopening of assessment u/s 147 - Non-disclosure of the cost of purchase of penny shares - The High Court noted that To our query as to whether there was any evidence that Petitioner had paid brokerage, or who was paid and the quantum, it was met with silence. We are not happy with the stand of the Revenue or the reasons. - The Bombay High Court ultimately held that the notice issued under Section 148 of the Act cannot be sustained, as there was no failure on the part of the petitioner to disclose material facts, and the reassessment was based on a change of opinion rather than new evidence or facts. Consequently, the order rejecting the petitioner's objections was also deemed unsustainable.....