Reassessment triggered on a change of opinion as to calculation of tax payable is invalid

Chanchal Bhagwatilal Gokhru Vs Union of India (Bombay High Court) HC examined the reasons recorded annexed to the Petition that are evidently premised on ‘seen from the assessment records’. The Assessment Officer (AO) records that the assessee claimed to have purchased shares of the penny stock scrips for a total of ₹ 33,09,976 and sold it for a consideration of ₹1,15,90,280/-. Therefore he held that the long term capital gain would be unexplained investment/income from other sources and not a capital gain as claimed by the assessee on the premise that entire transaction of purchase an...