The High Court held that the Assessing Officer (AO) could not...

The High Court held that the Assessing Officer (AO) could not reopen the assessment merely based on a belief that the average gross profit in the assessee's business line should be around 0.5% of the turnover. The court ruled that before concluding the original assessment, the AO should have sought an explanation from the assessee regarding the low net profit declared. Reopening the assessment on this ground amounted to a mere change of opinion, which is impermissible. The court also observed that the AO could have requested the KYC documents if there were doubts about the cash deposits, instead of treating it as a ground for reopening. The court emphasized that reopening must be based on fresh facts or information exposing the untruthfulness of previously disclosed facts, not merely a different inference from the same facts. The court allowed the assessee's petition, concluding that the reopening would amount to an impermissible review.