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


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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