https://www.taxtmi.com/caselaws?id=464388 ITAT KOLKATA allowed the taxpayer's appeal, holding the reassessment framed u/s 147 was not erroneous or prejudicial to revenue. The Tribunal found the excess director's salary issue was neither in the s.148 reasons nor noted initially, but held AO may make additions under Explanation (3) to s.147 if the matter emerges during proceedings; however, applying SC precedent in Alagendran Finance Ltd., the Tribunal concluded the reassessment could not be treated as raising the unrelated issue and the CIT's revision u/s 263 was unsustainable, so the assessment was restored in favor of the assessee. en-us Thu, 12 Sep 2024 00:00:00 +0530 Mon, 27 Oct 2025 20:01:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464388 ITAT KOLKATA allowed the taxpayer's appeal, holding the reassessment framed u/s 147 was not erroneous or prejudicial to revenue. The Tribunal found the excess director's salary issue was neither in the s.148 reasons nor noted initially, but held AO may make additions under Explanation (3) to s.147 if the matter emerges during proceedings; however, applying SC precedent in Alagendran Finance Ltd., the Tribunal concluded the reassessment could not be treated as raising the unrelated issue and the CIT's revision u/s 263 was unsustainable, so the assessment was restored in favor of the assessee. Case-Laws Income Tax Thu, 12 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464388