https://www.taxtmi.com/caselaws?id=759086 The ITAT Chennai held that reassessment u/s 147 was invalid where the AO reopened assessment to examine capital gains on land sale but instead made transfer pricing adjustments without addressing the original reason for reopening. The tribunal ruled that while Section 147 permits assessing other escaped income discovered during reassessment proceedings, this can only occur if the primary escaped income that triggered the Section 148 notice is first assessed. Since the AO failed to examine the capital gains issue that formed the basis for reopening and instead made unrelated TP adjustments, the reassessment order was quashed on jurisdictional grounds. The assessee's appeal was allowed. en-us Fri, 10 May 2024 00:00:00 +0530 Tue, 24 Sep 2024 09:05:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759086 The ITAT Chennai held that reassessment u/s 147 was invalid where the AO reopened assessment to examine capital gains on land sale but instead made transfer pricing adjustments without addressing the original reason for reopening. The tribunal ruled that while Section 147 permits assessing other escaped income discovered during reassessment proceedings, this can only occur if the primary escaped income that triggered the Section 148 notice is first assessed. Since the AO failed to examine the capital gains issue that formed the basis for reopening and instead made unrelated TP adjustments, the reassessment order was quashed on jurisdictional grounds. The assessee's appeal was allowed. Case-Laws Income Tax Fri, 10 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759086