Reassessment proceedings u/s 147 unsustainable on account of change of opinion

Gulshan Investment Co. Ltd. Vs ITO (ITAT Delhi) ITAT Delhi held that reassessment proceedings initiated u/s 147 of the Income Tax Act unsustainable as sufficient enquiry was made by AO on the impugned transaction and hence it tantamount to change of opinion on part of AO. Facts- The assessee is a registered Non-Banking Finance Company (NBFC) and is engaged in the business of purchase and sale of shares, securities, commodities and mutual funds, trading in derivatives, future & option and also derivative of commodities in commodity exchanges. AO after taking into consideration all the detai...