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The ITAT quashed the assessment proceedings due to jurisdictional defects in the notice under section 148. The ITO, Nabha incorrectly issued the notice when jurisdiction properly belonged to ACIT/DCIT, Mandi Gobindgarh. When the file was transferred, ACIT/DCIT failed to issue a fresh notice, rendering the proceedings legally invalid. On merits, the Tribunal also found the addition of Rs. 12,39,90,680/- as unexplained cash credits unjustified, as the assessee had demonstrated that deposits originated from legitimate sales of Harvester Combines and spares, supported by proper documentation including ledger accounts, sale invoices, and trading accounts. Following the principle in Ludhiana Steel Rolling Mills, such additions were impermissible when books of accounts had not been rejected. Appeal allowed.
The ITAT quashed the assessment proceedings due to jurisdictional defects in the notice under section 148. The ITO, Nabha incorrectly issued the notice when jurisdiction properly belonged to ACIT/DCIT, Mandi Gobindgarh. When the file was transferred, ACIT/DCIT failed to issue a fresh notice, rendering the proceedings legally invalid. On merits, the Tribunal also found the addition of Rs. 12,39,90,680/- as unexplained cash credits unjustified, as the assessee had demonstrated that deposits originated from legitimate sales of Harvester Combines and spares, supported by proper documentation including ledger accounts, sale invoices, and trading accounts. Following the principle in Ludhiana Steel Rolling Mills, such additions were impermissible when books of accounts had not been rejected. Appeal allowed.
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