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TMI Blog2015 (2) TMI 1142X X X X Extracts X X X X X X X X Extracts X X X X ..... s compared to the shortage in the earlier assessment years 2003-04 and 2004-05. The increase in shortage during the relevant period was mainly in some commodities whose total turnover was very less, at a figure less than ₹ 1.00 lakh in the entire year. We find that the AO has calculated the average shortage in various commodities purchased and sold by the assessee at 2.52% by taking average ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... TURVEDI, ACCOUNTANT MEMBER Appellant by : Shri Roopchand, Sr.DR Respondent by : Shri S.N. Divetia, AR ORDER PER G.C. GUPTA, VICE-PRESIDENT: This appeal by the Revenue for the Asstt.Year 2005-2006 is directed against the order of the CIT(A). 2. Only effective ground of the appeal of the Revenue is ground no.1, which is reproduced as under: 1. The ld.CIT(A) has erred in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ubmitted that it is clear case of change of opinion on the part of the AO which is not permissible under the provision of the Act. He submitted that it is now well settled that reassessment cannot be made on mere change of opinion. He referred to table given in the appellate order of the CIT(A) at page no.8, which shows that main commodities purchased and sold by the assessee during the year shows ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ier assessment years 2003-04 and 2004-05. The increase in shortage during the relevant period was mainly in some commodities whose total turnover was very less, at a figure less than ₹ 1.00 lakh in the entire year. We find that the AO has calculated the average shortage in various commodities purchased and sold by the assessee at 2.52% by taking average of the shortage in various commodities ..... X X X X Extracts X X X X X X X X Extracts X X X X
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