Re-Assessment can not be initiated just because AO feels he failed to verify things properly during regular Assessment

RELEVANT PARAGRAPH  6. We feel that the Writ Petition’, have to succeed because the contentions as raised on behalf of the counsel for the petitioner are well founded. The only reason which has been given seeking re-opening of the assessment for the years 1997-98 and 1998-99 is that suppression of sales have taken place on account of the fact that when average price of the closing stock is multiplied with the quantity of the sales in the year then the value of the sales would be at a higher figure than that as declared by the assessee. Clearly, there is no new material which is alleged ...