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ITAT affirmed that the reopening of assessment under section 147 was invalid and dismissed Revenue's grounds. The AO had conducted a detailed original assessment under section 143(3) read with section 144C(3) after considering the Taxpayer's exhaustive documentary submissions, including a submission dated 05.03.2015, and had allowed exemptions under sections 10A and 10AA. The reasons to believe did not disclose any fresh tangible material arising post-assessment; reliance on records from a subsequent year or on material already available at the time of original assessment cannot sustain reassessment. Consequently, the reassessment was held to be a review in substance, jurisdictionally impermissible, and the Taxpayer's exemptions under 10A/10AA were upheld.
ITAT affirmed that the reopening of assessment under section 147 was invalid and dismissed Revenue's grounds. The AO had conducted a detailed original assessment under section 143(3) read with section 144C(3) after considering the Taxpayer's exhaustive documentary submissions, including a submission dated 05.03.2015, and had allowed exemptions under sections 10A and 10AA. The reasons to believe did not disclose any fresh tangible material arising post-assessment; reliance on records from a subsequent year or on material already available at the time of original assessment cannot sustain reassessment. Consequently, the reassessment was held to be a review in substance, jurisdictionally impermissible, and the Taxpayer's exemptions under 10A/10AA were upheld.
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