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2022 (9) TMI 99 - AT - Income TaxReopening of assessment u/s 147 - addition attributable to the reasons recorded - relation between the reasons recorded and the additions made - Assessee had made huge cash deposits in bank accounts - Whether in the absence of any addition made on the vary reasons recorded, no further addition in this case is warranted? - HELD THAT:- We have gone through the record and find that there is no relation between the reasons recorded and the additions made. As per the record before us, the AO has not enquired about the deposits in the bank and no addition has been made on account of any of the amounts received on 10 occasions as mentioned in the reasons recorded. Since, no addition has been made on the reasons recorded and since the additions made have no relation with the reasons recorded while reopening the case and cannot be attributable to the reasons recorded, hold that the Assessing Officer had deficiency of jurisdiction in assessing any other income unrelated to the reasons recorded and owing to the facts of the instant case, the Explanation 3 to Section 147 is not attracted. - Decided in favour of assessee.
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