Reopening of assessment is on account of “change of opinion” and hence the reopening is not valid.

Last updated: 03 March 2021
Quick Summary
The Income Tax Appellate Tribunal ruled that the reopening of assessment for M/s. Rajarathnam's Jewels was invalid. The reopening was based on the Assessing Officer's 'change of opinion' regarding excess gold stock found during a survey. The Tribunal found that the stock belonged to customers and family members, held as a metal loan, and was not part of the assessee's business inventory. Therefore, the assessment could not be validly reopened on this basis.

Court :
ITAT Bangalore

Brief :
All these appeals filed by the assessee are directed against the common order dated 30.3.2017 passed by Ld. CIT(A)-7, Bengaluru and they relate to the assessment years 2006-07 to 2012-13. Allthese appeals were heard together and hence they are being disposed of by this common order, for the sake of convenience.

Citation :
ITA 1344/BANG/2017

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1 Year PLAN
1999
(Excl. of GST ₹359)

BEST VALUE
2 Years PLAN
3499
(Excl. of GST ₹629)

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