Reopening u/s. 148 merely on the basis of change of opinion is bad-in-law

GCK Stock Private Limited Vs ITO (ITAT Jaipur) ITAT Jaipur held that reopening under section 148 r.w.s. 148A is bad-in-law and liable to be quashed in as much as reopening was merely on the basis of change of opinion. Accordingly, appeal of assessee allowed and reopening quashed. Facts- The firm is a trader in securities market. There was credible information with the Department that the assessee was engaged in reversal trades in illiquid Stock Options leading to pre-meditated loss of Rs. 4,96,87,796/-. It was gathered from the information that the assessee has executed many non-genuine trades...