https://www.taxtmi.com/caselaws?id=772348 ITAT Ahmedabad quashed reassessment proceedings initiated by AO beyond four years as invalid. The Tribunal held that reopening was unjustified since assessee had not received dividend income during the assessment year, making section 14A disallowance inapplicable. Additionally, NSEL-related income of Rs. 244.98 crores pertained to a different assessment year (2011-12) and was previously deleted on appeal. Following jurisdictional HC precedent, AO cannot make additions on grounds not forming part of recorded reasons for reopening. Reassessment order quashed as without jurisdiction, and all additions including under sections 43(5), 73, and 40A(2)(b) were deleted. en-us Tue, 12 Nov 2024 00:00:00 +0530 Sat, 07 Jun 2025 08:32:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772348 ITAT Ahmedabad quashed reassessment proceedings initiated by AO beyond four years as invalid. The Tribunal held that reopening was unjustified since assessee had not received dividend income during the assessment year, making section 14A disallowance inapplicable. Additionally, NSEL-related income of Rs. 244.98 crores pertained to a different assessment year (2011-12) and was previously deleted on appeal. Following jurisdictional HC precedent, AO cannot make additions on grounds not forming part of recorded reasons for reopening. Reassessment order quashed as without jurisdiction, and all additions including under sections 43(5), 73, and 40A(2)(b) were deleted. Case-Laws Income Tax Tue, 12 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772348