https://www.taxtmi.com/caselaws?id=460646 ITAT Kolkata held that when assessment is reopened for specific accommodation entries from four bogus entities, AO cannot make additions for unrelated items discovered during reassessment proceedings. The seventeen entities for which additions were made were not connected to the original four accommodation providers mentioned in reopening reasons. Section 147 requires additions to relate to the specific issue for which assessment was reopened. Since no addition was made for the original accommodation entries, AO cannot add other escaped income items without fresh reopening proceedings. CIT(Appeals) correctly deleted the unrelated additions. Appeal decided against revenue. en-us Tue, 20 Sep 2022 00:00:00 +0530 Fri, 07 Feb 2025 19:19:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460646 ITAT Kolkata held that when assessment is reopened for specific accommodation entries from four bogus entities, AO cannot make additions for unrelated items discovered during reassessment proceedings. The seventeen entities for which additions were made were not connected to the original four accommodation providers mentioned in reopening reasons. Section 147 requires additions to relate to the specific issue for which assessment was reopened. Since no addition was made for the original accommodation entries, AO cannot add other escaped income items without fresh reopening proceedings. CIT(Appeals) correctly deleted the unrelated additions. Appeal decided against revenue. Case-Laws Income Tax Tue, 20 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460646