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ITAT allowed the assessee's appeal, holding that the reassessment was not sustained insofar as the AO's addition for non-deduction of TDS was concerned. The Tribunal found that the reasons recorded for reopening related to alleged bogus interest expenditure, whereas the AO's assessment order contained no disallowance on that ground but instead made an addition for failure to deduct TDS on interest. Because the addition in the assessment did not correspond to the recorded reasons for reopening, the addition was held to be legally untenable. The ITAT set aside the CIT(A)'s order and directed the AO to delete the impugned addition, allowing the assessee's appeal.
ITAT allowed the assessee's appeal, holding that the reassessment was not sustained insofar as the AO's addition for non-deduction of TDS was concerned. The Tribunal found that the reasons recorded for reopening related to alleged bogus interest expenditure, whereas the AO's assessment order contained no disallowance on that ground but instead made an addition for failure to deduct TDS on interest. Because the addition in the assessment did not correspond to the recorded reasons for reopening, the addition was held to be legally untenable. The ITAT set aside the CIT(A)'s order and directed the AO to delete the impugned addition, allowing the assessee's appeal.
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