Manan Trading Co. Pvt. Ltd. v. Dy. CIT (2022) 449 ITR 587 (Bom.)(HC)

S. 147 : Reassessment-After the expiry of four years-Estimate of gross profit-Reassessment notice to make addition of 5 percent of turnover instead of 1 percent addition was made in scrutiny assessment-Change of opinion-Notice and order disposing the objection was quashed. [S. 148, Art. 226]

The notice of reassessment was issued on the ground the Assessing Officer has had added back only 1 per cent. of the total turnover or sales to the income of the assessee instead of adding back 5 per cent. On writ allowing the petition the Court held that  there was nothing to indicate why it should be 5 per cent. Accordingly the notice and order disposing the objection was quashed. (AY. 2013-14)