If re-assessment order quashed than penalty levied has no legs to stand

Madhya Gujarat Vij Company Ltd Vs ACIT (ITAT Ahmedabad) As held by the Co-ordinate Bench of this Tribunal, the very reopening of assessment itself is bad in law. Based on change of opinion and there is no failure on the part of the assessee in declaring its income. Since the quantum appeal itself is being quashed, the penalty levied as against the reassessment order for furnishing inaccurate particulars has no legs to stand and the same is liable to be quashed. FULL TEXT OF THE ORDER OF ITAT AHMEDABAD This appeal is filed by the Assessee as against the Appellate order dated 20.09.2022 passed b...