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Reassessment initiated beyond three years was held jurisdictionally invalid because statutory sanction was obtained from an incompetent authority, and the reassessment travelled beyond the recorded reasons. The reopening was to verify specific bank cash withdrawals and deposits, which were examined and accepted on the assessee's response, but the AO proceeded to make an addition for alleged bogus purchases that was neither the basis of the 148A(b) notice nor the 148A(d) order. Consequently, the appellate authority's direction to delete the disallowance was sustained, and the Revenue's challenge was rejected. - ITAT
Reassessment initiated beyond three years was held jurisdictionally invalid because statutory sanction was obtained from an incompetent authority, and the reassessment travelled beyond the recorded reasons. The reopening was to verify specific bank cash withdrawals and deposits, which were examined and accepted on the assessee's response, but the AO proceeded to make an addition for alleged bogus purchases that was neither the basis of the 148A(b) notice nor the 148A(d) order. Consequently, the appellate authority's direction to delete the disallowance was sustained, and the Revenue's challenge was rejected. - ITAT
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