https://www.taxtmi.com/caselaws?id=774815 ITAT Delhi held that reassessment under section 147 was invalid as AO exceeded jurisdiction by making additions on issues not covered in recorded reasons for reopening. AO recorded satisfaction regarding INR 1.84 crores accommodation entry from M/s. Concise Exim Pvt. Ltd. but made no addition on this amount. Instead, AO treated entire bank credits of INR 1,29,43,40,550/- as accommodation entries and added 2% commission as unexplained income. Tribunal cancelled reassessment order citing ATS Infrastructure Ltd. precedent that AO cannot improve recorded reasons. Additionally, disallowance of business expenses was deleted as expenses were genuine day-to-day business costs, not related to exempt income. en-us Mon, 30 Jun 2025 00:00:00 +0530 Tue, 15 Jul 2025 08:39:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774815 ITAT Delhi held that reassessment under section 147 was invalid as AO exceeded jurisdiction by making additions on issues not covered in recorded reasons for reopening. AO recorded satisfaction regarding INR 1.84 crores accommodation entry from M/s. Concise Exim Pvt. Ltd. but made no addition on this amount. Instead, AO treated entire bank credits of INR 1,29,43,40,550/- as accommodation entries and added 2% commission as unexplained income. Tribunal cancelled reassessment order citing ATS Infrastructure Ltd. precedent that AO cannot improve recorded reasons. Additionally, disallowance of business expenses was deleted as expenses were genuine day-to-day business costs, not related to exempt income. Case-Laws Income Tax Mon, 30 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774815