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ITAT quashed reassessment proceedings under Section 148 after finding the PCIT's approval was granted mechanically without proper application of mind, contrary to established precedent requiring judicial examination of relevant material. The tribunal identified variance between the AO's recorded reasons and PCIT's approval, rendering the notice invalid per Supreme Court guidance in Teleperformance Global. Regarding substantive issues, ITAT deleted additions for alleged unaccounted production based on electricity consumption variations, holding no evidence existed of off-books purchases or sales, and rejected the CIT(A)'s averaging methodology. The tribunal also deleted bogus purchase additions following Prime Steel Industries precedent, allowing the assessee's appeal entirely while dismissing the department's cross-appeal on all grounds.
ITAT quashed reassessment proceedings under Section 148 after finding the PCIT's approval was granted mechanically without proper application of mind, contrary to established precedent requiring judicial examination of relevant material. The tribunal identified variance between the AO's recorded reasons and PCIT's approval, rendering the notice invalid per Supreme Court guidance in Teleperformance Global. Regarding substantive issues, ITAT deleted additions for alleged unaccounted production based on electricity consumption variations, holding no evidence existed of off-books purchases or sales, and rejected the CIT(A)'s averaging methodology. The tribunal also deleted bogus purchase additions following Prime Steel Industries precedent, allowing the assessee's appeal entirely while dismissing the department's cross-appeal on all grounds.
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