The assessment order was challenged on the grounds of validity of reopening after four years, based on a...

The assessment order was challenged on the grounds of validity of reopening after four years, based on a change of opinion and borrowed satisfaction. The assessee contended that there were no purchase or sale transactions on the National Spot Exchange Limited (NSEL) during the relevant assessment year. The statutory auditor's report u/s 142A confirmed no stock pertaining to NSEL transactions. However, the Assessing Officer reopened the assessment solely based on outstanding dues payable by the assessee to NSEL from earlier years, without considering the available material and audit report. The High Court held that the reopening notice was issued without application of mind, amounting to a change of opinion and borrowed satisfaction, as the ..... .....

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