The assessee disclosed F&O losses in return, which were examined in scrutiny. Reopening after four years was initiated solely on insight portal information without independent verification. The Court held this to be “borrowed satisfaction” and a change of opinion, as no tangible new material or failure to disclose was shown. Notice was quashed. (AY 2013-14)
Rikin Industries v. ITO (2025) 303 Taxman 393 (Guj)(HC)
S. 147 : Reassessment-After the expiry of four years-Futures & options loss-Borrowed satisfaction-No failure to disclose-Notice quashed [S. 71, 148, Art. 226]
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