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 co

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