Munjal M Jaykrishna Family Trust v. ITO (2023) 293 Taxman 665 /333 CTR 364 (Guj.)(HC)

S. 147 : Reassessment-With in four years-Long term capital gains from equities-Instances of insider trading-Formation of opinion based on prima facie, but precise facts-Strong foundation for invoking reassessment-Challenge to notice was dismissed.[S. 10(38), 45, 148, Art. 226]

The assessee challenged the notice of reassessment.   Court held that  the Assessing Officer had found that there was likelihood of acts and instance of insider trading by assessee.  Beneficiaries, it was noticed, were promoters group consisting of family member  and the assessee was prima facie found to have earned income which was chargeable to tax but same was not shown in return of income. Accordingly there being a strong foundation for invoking reassessment, challenge to impugned notice under section 148 was  dismissed. AY. 2017-18)