Reopening based on factual inadvertent error not sustainable

Brief of the Case

Delhi High Court held In the case of Dr. Ajit Gupta vs. ACIT that the reason for reopening of the assessment was a mistaken factual premise that the Assessee had changed the system of accounting from the mercantile to the cash system. It was more than adequately explained by the Assessee that this was an inadvertent error. The Assessee has convincingly shown that he has consistently been following the mercantile system of accounting not only for AYs in question but for the earlier and

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