The assessee, a partnership firm engaged in real estate development, sold four flats, of which two were sold below the stamp duty value. The Assessing Officer invoked section 43CA, treating the difference as escaped income. Held that since the difference between the stamp duty value and agreement value was less than 5%, the addition under section 43CA was unsustainable. Accordingly, the Assessing Officer was directed to delete the addition.  Reopening of assessment was quashed on the ground of change of opinion. (AY 2016-17)