Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Undisclosed receipts were added to gross profit by the AO, but the assessee claimed corresponding expenditure. CIT(A) deleted the addition, terming it double assessment. The department did not rebut that the addition was double assessment or deny the corresponding expenditure. ITAT held that the AO could not brush aside the assessee's claim of corresponding expenditure, which was duly considered by CIT(A). The department's grounds did not dispute the correctness of the expenditure items. The addition was rejected accordingly.
Undisclosed receipts were added to gross profit by the AO, but the assessee claimed corresponding expenditure. CIT(A) deleted the addition, terming it double assessment. The department did not rebut that the addition was double assessment or deny the corresponding expenditure. ITAT held that the AO could not brush aside the assessee's claim of corresponding expenditure, which was duly considered by CIT(A). The department's grounds did not dispute the correctness of the expenditure items. The addition was rejected accordingly.
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