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The ITAT held that the reassessment initiated under s.148 was invalid because the assessee complied with all notices and there was no suppression of material facts warranting reopening; consequently the reassessment proceedings are non est. Having found the reassessment void ab initio, the revisionary order passed by the AO under s.263 lacks jurisdiction and is set aside. The appeal by the assessee is allowed, with directions that no addition on account of alleged bogus expenditure or interest under s.234A for the specified period shall be sustained pursuant to the impugned proceedings. The AO is precluded from pursuing the contested reassessment and revision further.
The ITAT held that the reassessment initiated under s.148 was invalid because the assessee complied with all notices and there was no suppression of material facts warranting reopening; consequently the reassessment proceedings are non est. Having found the reassessment void ab initio, the revisionary order passed by the AO under s.263 lacks jurisdiction and is set aside. The appeal by the assessee is allowed, with directions that no addition on account of alleged bogus expenditure or interest under s.234A for the specified period shall be sustained pursuant to the impugned proceedings. The AO is precluded from pursuing the contested reassessment and revision further.
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