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2014 (5) TMI 990 - ITAT AHMEDABADValidity of Re-opening of assessment – protective assessment - Held that:- In the block assessment proceedings as well as in re-opening assessment proceedings u/s 147 of the Act, the additions have been made in respect of the same bank account and the same amount which has been added in the block assessment on substantive basis - additions made in the reopening assessment proceedings are on the protective basis - Revenue has not controverted the contention of the assessee that the same addition has been affirmed up to the stage of ITAT in block assessment proceedings - the additions made u/s 158BC of the Act have become final – the AO is directed to delete the addition made on protective basis in all the three assessment years – Decided in favour of Assessee.
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