https://www.taxtmi.com/highlights?id=85677 ITAT upheld the reopening of assessment under s.147 as it was based on new facts not previously available to the AO, rejecting assessee's claim of mere "change of opinion." Regarding bogus purchases from six entities, ITAT confirmed CIT(A)'s approach of quantifying profit at 10% GP rate (less 1.53% already disclosed), sustaining addition of Rs. 1,22,08,002. CIT(A) reasonably estimated profits based on prevailing GP rates in rice miller/trader business for goods procured from grey market rather than bogus entities. On unaccounted investments, ITAT affirmed AO's addition based on "peak purchase" amount appearing in bogus concern's account, considering it represented unexplained investment in bogus billing operations. en-us Wed, 12 Feb 2025 08:30:05 +0530 Wed, 12 Feb 2025 08:30:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=85677 ITAT upheld the reopening of assessment under s.147 as it was based on new facts not previously available to the AO, rejecting assessee's claim of mere "change of opinion." Regarding bogus purchases from six entities, ITAT confirmed CIT(A)'s approach of quantifying profit at 10% GP rate (less 1.53% already disclosed), sustaining addition of Rs. 1,22,08,002. CIT(A) reasonably estimated profits based on prevailing GP rates in rice miller/trader business for goods procured from grey market rather than bogus entities. On unaccounted investments, ITAT affirmed AO's addition based on "peak purchase" amount appearing in bogus concern's account, considering it represented unexplained investment in bogus billing operations. Highlights Income Tax Wed, 12 Feb 2025 08:30:05 +0530 https://www.taxtmi.com/highlights?id=85677