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Reopening under reassessment must stand or fall on the recorded reasons; where the basis was an alleged reduction in closing work in progress, the Court held that this did not disclose escapement of income because a lower closing work in progress would reduce profit rather than create taxable income. After the assessee pointed out this defect, the Assessing Officer could not sustain the notice by shifting to a new allegation of suppression of sales or other income. The consistent method of valuing closing work in progress had also not been unsettled earlier. The notice and the order rejecting objections were quashed.
Reopening under reassessment must stand or fall on the recorded reasons; where the basis was an alleged reduction in closing work in progress, the Court held that this did not disclose escapement of income because a lower closing work in progress would reduce profit rather than create taxable income. After the assessee pointed out this defect, the Assessing Officer could not sustain the notice by shifting to a new allegation of suppression of sales or other income. The consistent method of valuing closing work in progress had also not been unsettled earlier. The notice and the order rejecting objections were quashed.
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