Reopening of Assessment and Work-in-Progress Disallowance Unjustified Due to Change of Opinion by AO: ITAT

The Income Tax Appellate Tribunal (ITAT) has ruled that reopening of an assessment and the disallowance of work-in-progress costs were unjustified due to a mere change of opinion by the Assessing Officer (AO). The Tribunal found that such changes must be based on substantial evidence rather than shifting opinions. This ruling underscores the importance of consistency and evidence-based decision-making in tax assessments. It aims to protect taxpayers from arbitrary or unjustified actions and ensures that assessment processes remain fair and transparent.