Reopening assessment without independent opinion invalid.

The HC held that the Assessing Officer could not reopen the assessment for AY 2013-14 merely relying on information from the insight portal without forming an independent opinion based on the assessee's records. The assessee had disclosed and offered to tax the loss from F&O transactions, which was scrutinized and accepted during regular assessment. Reopening on the same issue amounts to a change of opinion, which is impermissible. The reopening lacked tangible material and application of mind, rendering it invalid. The Court decided in favor of the assessee. .....

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