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2022 (12) TMI 494 - ITAT AHMEDABADValidity of re-opening of assessment u/s 147 - parity between reasons recorded and notice issued - reasons to believe - addition on account of undisclosed receipts out of sale of plots of land - HELD THAT:- As in the assessment order, we note that AO has not made any additions and nor even discussed the issue on the basis of which the reassessment proceedings were initiated. Accordingly, in our view, the order passed by the AO u/s 147/148 of the Act is liable to be set aside on the grounds of jurisdiction, in light of the discussion above. Having held that additions made during reassessment proceedings deserve to be set aside on grounds of jurisdiction, we are not going into the individual grounds with respect to merits of the case. Appeal of the Department is dismissed.
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