https://www.taxtmi.com/caselaws?id=252046 The tribunal dismissed the appeal of the Revenue, upholding the CIT(A)'s order quashing the reassessment proceedings under Sections 147/148 and deleting the additions made by the A.O. The reassessment was deemed impermissible as it was based on a change of opinion. The additions representing unrecorded sales were deleted as no evidence of diversion was found. Additionally, the direction to allow set off of income from unrecorded sales against already taxed income was upheld. The tribunal found the CIT(A)'s decisions rational and evidence-based, leading to the appeal dismissal on 26/09/2014. en-us Fri, 26 Sep 2014 00:00:00 +0530 Thu, 09 Oct 2014 06:28:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252046 The tribunal dismissed the appeal of the Revenue, upholding the CIT(A)'s order quashing the reassessment proceedings under Sections 147/148 and deleting the additions made by the A.O. The reassessment was deemed impermissible as it was based on a change of opinion. The additions representing unrecorded sales were deleted as no evidence of diversion was found. Additionally, the direction to allow set off of income from unrecorded sales against already taxed income was upheld. The tribunal found the CIT(A)'s decisions rational and evidence-based, leading to the appeal dismissal on 26/09/2014. Case-Laws Income Tax Fri, 26 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252046