ITAT allowed the assessee's appeal, quashing reassessment proceedings and consequent additions. The Tribunal held the notice under section 148 issued on 30/07/2022 barred by limitation, the six-year period having expired on 31/03/2022, and reiterated that the earlier 30/06/2021 notice could not be salvaged by TOLA. Independently, the section 148A(b) notice dated 27/05/2022 was held invalid for non-supply of the information/material forming the basis of the reasons, thereby vitiating reopening under section 147. Further, additions under section 69A were not sustained: allegations of VAT evasion and unexplained cash were uncorroborated, speculative and unsupported by any cogent cash-trail or material.
ITAT allowed the assessee's appeal, quashing reassessment proceedings and consequent additions. The Tribunal held the notice under section 148 issued on 30/07/2022 barred by limitation, the six-year period having expired on 31/03/2022, and reiterated that the earlier 30/06/2021 notice could not be salvaged by TOLA. Independently, the section 148A(b) notice dated 27/05/2022 was held invalid for non-supply of the information/material forming the basis of the reasons, thereby vitiating reopening under section 147. Further, additions under section 69A were not sustained: allegations of VAT evasion and unexplained cash were uncorroborated, speculative and unsupported by any cogent cash-trail or material.
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