Reopening Without New Material & on Mere Change of Opinion invalid

Deepak Natvarlal Pankhiyani (HUF) Vs ACIT (Gujarat High Court) The petitioner, Deepak Natvarlal Pankhiyani (HUF), engaged in trading shares and securities, filed their original income tax return for the Assessment Year (AY) 2015-16 on September 21, 2015, declaring a total loss of ₹2,00,23,842. The case was selected for limited scrutiny by issuing a notice under Section 143(2) of the Income Tax Act, 1961, on September 20, 2016, focusing on “Derivative (Future) transactions.” The petitioner responded with detailed information regarding these transactions. After further scrutiny, th...