Change of Opinion cannot be alleged If AO finds Fresh Tangible Materials

Mamta Gupta Vs Addl./Joint/Deputy/Assistant Commissioner of Income Tax/ITO National Faceless Assessment Centre, Delhi & Ors. (Delhi High Court) HC held that despite lapse of four years and a scrutiny assessment, there is fresh tangible material in the present case in the form of information of beneficiaries of bogus LTCL/STCL report prepared by the office of Deputy Director of Income Tax (Investigation) which reveals that Mahanivesh (India) Ltd. is a penny stock whose share price was manipulated in trade by way of a complex web of pre-arranged or artificial transactions to book long term...