Reassessment Quashed for Pure Change of Opinion

Khajamohiaddin Ghousemohiaddin Syed Vs ITO (ITAT Mumbai)

Second Bite at the Same Cherry Not Allowed— Reopening on Same Issue is Pure Change of Opinion Reassessment Quashed

Assessee engaged in civil construction filed revised return declaring income of Rs.40,01,190/-. Original assessment u/s 143(3) r.w.s. 144 dated 28/03/2016 determined income at Rs.1,33,63,668/- by applying presumptive rate of 8% u/s 44AD on gross receipts of Rs.16,70,45,850/-, after rejecting the books due to absence of supporting evidenc

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