https://www.taxtmi.com/caselaws?id=457017 The ITAT Delhi quashed the reassessment proceedings under Section 148 as the AO failed to establish non-disclosure of material facts by the assessee. The Tribunal held that CIT(A) lacked jurisdiction to enhance assessment by adding designated return income and treating land lease as revenue subsidy, as these were new sources not considered by the AO. The enhancement of Rs. 1730.08 crores was deleted since lands were leased, not transferred. Depreciation disallowance was reversed as there was no capital subsidy to reduce written down value. Interest on deep discount bonds was allowed on accrual basis as Section 43B(e) applies only to financial institution borrowings, not public bonds. en-us Tue, 08 Aug 2023 00:00:00 +0530 Fri, 30 Aug 2024 16:05:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457017 The ITAT Delhi quashed the reassessment proceedings under Section 148 as the AO failed to establish non-disclosure of material facts by the assessee. The Tribunal held that CIT(A) lacked jurisdiction to enhance assessment by adding designated return income and treating land lease as revenue subsidy, as these were new sources not considered by the AO. The enhancement of Rs. 1730.08 crores was deleted since lands were leased, not transferred. Depreciation disallowance was reversed as there was no capital subsidy to reduce written down value. Interest on deep discount bonds was allowed on accrual basis as Section 43B(e) applies only to financial institution borrowings, not public bonds. Case-Laws Income Tax Tue, 08 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457017