High Court rules reopening of tax assessment invalid due to change of opinion; AO lacks jurisdiction on unsecured loans.

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....The High Court held that the Assessing Officer (AO) had specifically called for and considered information regarding unsecured loans during the original assessment proceedings u/s 143(3) of the Income Tax Act. The assessee had furnished the requisite details. Merely a difference between the unsecured loan amounts in the books and the AO's addition cannot be grounds for reopening assessment on the premise of escaped income. The AO had already examined the issue during regular assessment. The reliance on the Supreme Court's decision in Income Tax Officer vs. Techspan India Private Limited is misplaced as that case dealt with failure to consider certain aspects, unlike the present case where the AO had considered the unsecured loans. Issuing a.........