Reassessment cannot be initiated based on a mere change in opinion: MP HC

Susheel Kumar Shankarlal Vs ITO And Others (Madhya Pradesh High Court)

In the case of Susheel Kumar Shankarlal Vs ITO and Others before the Madhya Pradesh High Court, the petitioner contested the reopening of assessments for the financial years 1999-2000 and 2000-2001 under Section 148 of the Income Tax Act. The dispute arose after the petitioner had disclosed all income, including unrecorded transactions, with gross profits calculated at 7.5% for unrecorded sales and 12.5% for recorded sales. The Assessing Officer finalized the profit rate at 8% and issued a demand notice

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