Reopening of Assessment Based on Change of Opinion Unjustifiable: ITAT Ahmedabad

Gayatri Creatives Vs ACIT (ITAT Ahmedabad) ITAT Ahmedabad held that initiation of reopening of assessment based on mere change of opinion and not taking into account the work-in-progress method of accounting followed by the assessee is unjustifiable and liable to be quashed. Facts- The assessee filed his return for Rs.42,98,920/-. The assessment u/s. 143(3) of the Income Tax Act, 1961 was completed on 28.03.2013 thereby assessing the total income at Rs.43,26,030/-. AO noticed that the Balance Sheet of the assessee as on 31.03.2010 showed work-in-progress at Rs.7,85,89,164/- and in the Profit &...