Reassessment under Section 147 quashed where AO lacked reason to believe; s.68 not attracted and reopening was change of opinion

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....ITAT quashed reassessment initiated u/s 147 as the AO lacked valid reasons to form belief that income of the assessee had escaped assessment. The tribunal found evidentiary support for sales to an unnamed counterparty, receipt of sale proceeds through banking channels, and no rebuttal by the AO to impugn genuineness; mere non-filing of returns by the counterparty did not suffice to treat receipts as unexplained cash credit u/s 68 or to constitute a reason to form belief under s.147. Reopening was also held to amount to impermissible change of opinion since identical sales were examined and accepted in the original s.143(3) assessment; reassessment was therefore invalid.....