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    <title>2023 (11) TMI 27 - ITAT DELHI</title>
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    <description>The ITAT Delhi held that reassessment u/s 147 was invalid where additions were made on grounds different from those recorded in the reasons for reopening. The original reason concerned income claimed as exempt u/s 10(38) regarding trading in scrips, but additions were made u/s 68 for unexplained cash credit. The tribunal ruled that once jurisdiction is assumed for reopening u/s 148, the Assessing Officer cannot make additions for other income unless based on recorded allegations. Since the foundation for reopening was knocked out and additions made on unrelated grounds, the impugned additions were quashed in favor of the assessee.</description>
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    <pubDate>Fri, 06 Oct 2023 00:00:00 +0530</pubDate>
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      <title>2023 (11) TMI 27 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=445136</link>
      <description>The ITAT Delhi held that reassessment u/s 147 was invalid where additions were made on grounds different from those recorded in the reasons for reopening. The original reason concerned income claimed as exempt u/s 10(38) regarding trading in scrips, but additions were made u/s 68 for unexplained cash credit. The tribunal ruled that once jurisdiction is assumed for reopening u/s 148, the Assessing Officer cannot make additions for other income unless based on recorded allegations. Since the foundation for reopening was knocked out and additions made on unrelated grounds, the impugned additions were quashed in favor of the assessee.</description>
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      <pubDate>Fri, 06 Oct 2023 00:00:00 +0530</pubDate>
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