Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
ITAT upheld the validity of reopening under s.148 (reasons recorded, sanction obtained, survey-linked information), dismissing the challenge to jurisdiction and the plea for s.153C. However, the Tribunal allowed the appeal on substantive additions: it held that CIT(A) wrongly exercised powers under s.251(2) read with s.145(3) without applying accepted accounting/project completion methods, rendering those additions bad in law; consequential disallowances and construction-expense additions sustained by AO/CIT(A) were deleted. The cancellation of registration under s.12AA and related presumptive additions were not sustained, and the impugned additions are set aside in favour of the assessee.
ITAT upheld the validity of reopening under s.148 (reasons recorded, sanction obtained, survey-linked information), dismissing the challenge to jurisdiction and the plea for s.153C. However, the Tribunal allowed the appeal on substantive additions: it held that CIT(A) wrongly exercised powers under s.251(2) read with s.145(3) without applying accepted accounting/project completion methods, rendering those additions bad in law; consequential disallowances and construction-expense additions sustained by AO/CIT(A) were deleted. The cancellation of registration under s.12AA and related presumptive additions were not sustained, and the impugned additions are set aside in favour of the assessee.
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