https://www.taxtmi.com/caselaws?id=764029 ITAT Ahmedabad held that reassessment proceedings under section 147 were invalid where the AO recorded reasons for reopening based on escaped income regarding share and securities investments but made no additions on that specific issue. The tribunal ruled that when the basis for AO's belief vanishes due to no additions being made on the reopening grounds, the reassessment order becomes unsustainable. Consequently, any revision proceedings under section 263 based on such invalid reassessment cannot be sustained. The assessee's appeal was allowed, following precedents that prohibit additions on grounds not forming part of recorded reasons for reopening. en-us Tue, 31 Dec 2024 00:00:00 +0530 Thu, 02 Jan 2025 08:13:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764029 ITAT Ahmedabad held that reassessment proceedings under section 147 were invalid where the AO recorded reasons for reopening based on escaped income regarding share and securities investments but made no additions on that specific issue. The tribunal ruled that when the basis for AO's belief vanishes due to no additions being made on the reopening grounds, the reassessment order becomes unsustainable. Consequently, any revision proceedings under section 263 based on such invalid reassessment cannot be sustained. The assessee's appeal was allowed, following precedents that prohibit additions on grounds not forming part of recorded reasons for reopening. Case-Laws Income Tax Tue, 31 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764029