Reassessment Under Section 147 Invalid: AO's Mechanical Reliance on Portal Data Without Independent Verification Fails Legal Test

HC invalidated reassessment proceedings initiated under s.147 for AY 2014-15. AO's reliance solely on insight portal information regarding transactions with ASE Capital Markets Ltd was deemed mechanical and without independent application of mind. The assessee had fully disclosed F&O losses of Rs.41,56,218 in original return, accepted under s.143(3). AO failed to explain why only Rs.27,61,650 was considered non-genuine. No tangible material or verification supported the reopening, and AO's belief was based on borrowed satisfaction without considering existing assessment records. Court found no failure by assessee to disclose material facts, making reopening after four years unjustified as it merely reflected change of opinion. .....

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