https://www.taxtmi.com/caselaws?id=757599 MP HC set aside reassessment proceedings where AO reopened assessment solely based on change of opinion regarding GP rate determination. Court held that petitioner had disclosed all undisclosed sale transactions and AO had already assessed GP at 8%, leaving no failure justifying reopening. Relying on Kelvinator of India SC judgment, court ruled Section 147 cannot grant arbitrary power to reopen assessment based on mere change of opinion. Similar precedents from CEAT Ltd. and Financial Software Systems supported this position. Assessment proceedings quashed in favor of assessee. en-us Tue, 20 Aug 2024 00:00:00 +0530 Mon, 02 Sep 2024 17:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757599 MP HC set aside reassessment proceedings where AO reopened assessment solely based on change of opinion regarding GP rate determination. Court held that petitioner had disclosed all undisclosed sale transactions and AO had already assessed GP at 8%, leaving no failure justifying reopening. Relying on Kelvinator of India SC judgment, court ruled Section 147 cannot grant arbitrary power to reopen assessment based on mere change of opinion. Similar precedents from CEAT Ltd. and Financial Software Systems supported this position. Assessment proceedings quashed in favor of assessee. Case-Laws Income Tax Tue, 20 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757599