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ITAT quashed reassessment proceedings initiated u/s 148 against assessee. There was a difference between reasons communicated in notice u/s 148A(b) alleging bogus transactions of Rs. 50 lakh and subsequent order u/s 148A(d) making addition of Rs. 9.68 crore for purchases from non-filers. ITAT held initiation of proceedings itself was flawed as issues in 148A(b) notice were not carried into 148A(d) order. Following Banyan Real Estate Fund Mauritius, ITAT allowed assessee's appeal quashing reassessment notices and order.
ITAT quashed reassessment proceedings initiated u/s 148 against assessee. There was a difference between reasons communicated in notice u/s 148A(b) alleging bogus transactions of Rs. 50 lakh and subsequent order u/s 148A(d) making addition of Rs. 9.68 crore for purchases from non-filers. ITAT held initiation of proceedings itself was flawed as issues in 148A(b) notice were not carried into 148A(d) order. Following Banyan Real Estate Fund Mauritius, ITAT allowed assessee's appeal quashing reassessment notices and order.
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