https://www.taxtmi.com/caselaws?id=756525 Gujarat HC quashed reassessment notice u/s 148 for reopening assessment u/s 147. AO had already examined sundry creditors during regular assessment u/s 143(3) and disallowed 20% of total sundry creditors, which was under appeal before CIT(Appeals). Court held that AO cannot reopen assessment on same issue as it constitutes change of opinion. Violation of merger principle noted since matter was pending before appellate authority. Mere audit objection insufficient to assume jurisdiction for reopening assessment. Petition allowed. en-us Tue, 30 Jul 2024 00:00:00 +0530 Mon, 05 Aug 2024 07:05:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756525 Gujarat HC quashed reassessment notice u/s 148 for reopening assessment u/s 147. AO had already examined sundry creditors during regular assessment u/s 143(3) and disallowed 20% of total sundry creditors, which was under appeal before CIT(Appeals). Court held that AO cannot reopen assessment on same issue as it constitutes change of opinion. Violation of merger principle noted since matter was pending before appellate authority. Mere audit objection insufficient to assume jurisdiction for reopening assessment. Petition allowed. Case-Laws Income Tax Tue, 30 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756525