The ITAT set aside the assessment order under section 147,...

The ITAT set aside the assessment order under section 147, holding that the AO failed to comply with mandatory conditions under sections 147-151A. Regarding infrastructure fund additions, the Tribunal noted the AO issued a cryptic, non-speaking order without explaining the legal basis for additions. The assessment contained patent calculation errors, with incorrect column totals and misidentified infrastructure fund components. Following precedent from the assessee's own cases for AYs 2013-14 and 2014-15, the Tribunal determined that even if accretions to the infrastructure fund were taxable income, they would remain exempt under section 11. The assessment was vitiated by computational errors and lack of proper reasoning. Appeal allowed.