Tribunal dismisses appeal and cross objection, deeming reassessment unjustified.

The Tribunal upheld the CIT(A)'s decision to quash the reassessment order dated 01.03.2013, leading to the deletion of additions made by the Assessing Officer. The Tribunal dismissed the Revenue's appeal and the assessee's cross objection, as the reassessment was deemed unjustified due to an invalid reason for reopening the assessment. Consequently, the additions on merits were irrelevant and did not survive, resulting in the dismissal of both the appeal and cross objection.

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Issues:
1. Justification of quashing the reassessment order dated 01.03.2013 by the CIT(A).

Detailed Analysis:

Revenue's Appeal:
The Revenue raised the issue of whether the CIT(A) was justified in quashing the reassessment order dated 01.03.2013. The case involved the assessment year 2006-2007 and the assessee, a software development and sales company, had initially filed its return with one PAN which was later changed by the Department. The Assessing Officer issued a notice for reassessment under section 148 of the I.T. Act, claiming that no return was filed by the assessee for the concerned year. The CIT(A) quashed the reassessment order, stating that the reason for reopening the assessment was invalid as the assessee had indeed filed its return with the original PAN. The CIT(A) observed that the new PAN was allotted after the original return was filed, and therefore, the reassessment proceedings were unjustified. The additions made by the Assessing Officer were subsequently deleted by the CIT(A).

Assessee's Cross Objection:
The assessee's cross objection raised grounds regarding the merits of the addition. However, since the reassessment order was quashed by the CIT(A), the addition on merits was deemed irrelevant and did not survive. Consequently, the cross objection was dismissed as infructuous.

In conclusion, the Tribunal dismissed the appeal filed by the Revenue and the cross objection by the assessee. The reassessment order was quashed by the CIT(A) based on the invalid reason for reopening the assessment, leading to the deletion of the additions made by the Assessing Officer. The Tribunal upheld the CIT(A)'s decision, resulting in the dismissal of both the appeal and the cross objection.

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