https://www.taxtmi.com/caselaws?id=754763 The Gujarat HC upheld ITAT's decision favoring the assessee in a reopening of assessment case under section 147. The assessing officer had reopened assessment after 4 years to disallow depreciation and reduce returned loss. The court found that reopening was based solely on profit and loss account details already filed by the assessee, without any tangible materials or failure by assessee to disclose material facts. Following Kelvinator of India precedent, the court held the reopening constituted mere change of opinion and was therefore invalid in law. en-us Mon, 10 Jun 2024 00:00:00 +0530 Fri, 28 Jun 2024 18:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754763 The Gujarat HC upheld ITAT's decision favoring the assessee in a reopening of assessment case under section 147. The assessing officer had reopened assessment after 4 years to disallow depreciation and reduce returned loss. The court found that reopening was based solely on profit and loss account details already filed by the assessee, without any tangible materials or failure by assessee to disclose material facts. Following Kelvinator of India precedent, the court held the reopening constituted mere change of opinion and was therefore invalid in law. Case-Laws Income Tax Mon, 10 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754763