Reopening of Assessment merely on the basis of change in opinion is invalid

Brief of the case:

The ITAT Ahmedabad in the case of Waves Food Private Limited vs. DCIT held that reopening of assessment to disallow provision for damaged goods returned is not valid as the issue had been specifically dealt by AO during the course of regular assessment and such disallowance by reopening the assessment is nothing but mere change opinion which cannot be reason for reopening the assessment.

 Facts of the case:

• The assessee company filed its return on 31.10.2005 declaring nil income and the regular assessment of the assessee was framed after making one disallowance regarding non-deduction of tax at source.

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