The reopening of assessment proceedings u/s 147 was valid as the Assessing Officer (AO) had received...

The reopening of assessment proceedings u/s 147 was valid as the Assessing Officer (AO) had received information about the assessee booking tax loss through trade in shares, which could not be considered a mere change of opinion. The AO provided independent findings regarding trading in shares of M/s. Radhe Developers Ltd., and the assessee's objections were not tenable. The decisions in NDTV, Calcutta Discount, Parshuram Potteries, and Bombay Stock Exchange cases were not relevant as the reopening was specific to trading in M/s. Radhe Developers Ltd.'s scrip and not just a second opinion. However, the disallowance of loss in share trading was not sustained as the AO and CIT(A) did not correlate the trading with price fluctuations of M/s. R..... .....

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