Genuineness of transaction examined during regular assessment cannot be base for reassessment

Gujarat Natural Resources Limited Vs ACIT (Gujarat High Court) Gujarat High Court held that details relating to share application money from the four entities was supplied by the assessee during regular assessment and AO was satisfied with the genuineness of the same. Hence reopening the assessment doubting the same entries on the basis of change of opinion is unsustainable. Facts- The challenge in this Special Civil Application filed under Article 226 of the Constitution is directed against notice dated 26.3.2018 issued by AO to the petitioner company u/s. 148 of the Income Tax Act, 1961 for ...