https://www.taxtmi.com/caselaws?id=763323 The ITAT Mumbai held that reopening of assessment u/s 147 was invalid where the AO recorded reasons alleging bogus purchases but the assessee had actually taken loans, not made purchases. The AO lacked clear understanding of the alleged income escapement when recording reasons for reopening. The court emphasized that recorded reasons are sacrosanct and cannot be changed later. Following CIT vs. Jet Airways, the tribunal ruled that AO cannot make additions on issues not mentioned in reopening reasons unless additions are made on the originally stated grounds. The assessment was decided in favor of the assessee. en-us Wed, 11 Dec 2024 00:00:00 +0530 Tue, 17 Dec 2024 09:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763323 The ITAT Mumbai held that reopening of assessment u/s 147 was invalid where the AO recorded reasons alleging bogus purchases but the assessee had actually taken loans, not made purchases. The AO lacked clear understanding of the alleged income escapement when recording reasons for reopening. The court emphasized that recorded reasons are sacrosanct and cannot be changed later. Following CIT vs. Jet Airways, the tribunal ruled that AO cannot make additions on issues not mentioned in reopening reasons unless additions are made on the originally stated grounds. The assessment was decided in favor of the assessee. Case-Laws Income Tax Wed, 11 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763323