https://www.taxtmi.com/caselaws?id=450019 ITAT Pune held that AO lacked jurisdiction to make addition under section 69 regarding commodity transaction profits when no addition was made for the specific item that formed the basis for reopening assessment under section 147. Following precedents from Bombay HC in Jet Airways, Delhi HC in Ranbaxy Laboratories, and Rajasthan HC in Shri Ram Singh, the tribunal ruled that AO cannot make additions for items other than those for which reasons were recorded in section 148 notice. Since AO chose not to add the commodity transaction profit of Rs. 15,884 that triggered the reopening, subsequent addition under section 69 was impermissible. Appeal allowed, addition deleted. en-us Wed, 21 Feb 2024 00:00:00 +0530 Sat, 24 Feb 2024 09:28:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450019 ITAT Pune held that AO lacked jurisdiction to make addition under section 69 regarding commodity transaction profits when no addition was made for the specific item that formed the basis for reopening assessment under section 147. Following precedents from Bombay HC in Jet Airways, Delhi HC in Ranbaxy Laboratories, and Rajasthan HC in Shri Ram Singh, the tribunal ruled that AO cannot make additions for items other than those for which reasons were recorded in section 148 notice. Since AO chose not to add the commodity transaction profit of Rs. 15,884 that triggered the reopening, subsequent addition under section 69 was impermissible. Appeal allowed, addition deleted. Case-Laws Income Tax Wed, 21 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450019