https://www.taxtmi.com/caselaws?id=462269 The ITAT Ahmedabad dismissed the Revenue's appeal regarding reopening of assessment under section 147. The tribunal held that additions made during reassessment proceedings on grounds different from those recorded in the reasons for escapement under section 148(2) were invalid. Following precedent from a Gujarat HC case, the tribunal ruled that the AO cannot make additions on grounds not forming part of the originally recorded reasons. Since the Revenue failed to establish that the additions were based on the grounds mentioned in the recorded reasons, the CIT(A)'s decision favoring the assessee was upheld. en-us Mon, 25 Jan 2021 00:00:00 +0530 Fri, 06 Jun 2025 19:24:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462269 The ITAT Ahmedabad dismissed the Revenue's appeal regarding reopening of assessment under section 147. The tribunal held that additions made during reassessment proceedings on grounds different from those recorded in the reasons for escapement under section 148(2) were invalid. Following precedent from a Gujarat HC case, the tribunal ruled that the AO cannot make additions on grounds not forming part of the originally recorded reasons. Since the Revenue failed to establish that the additions were based on the grounds mentioned in the recorded reasons, the CIT(A)'s decision favoring the assessee was upheld. Case-Laws Income Tax Mon, 25 Jan 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462269