Reopening under s.148 upheld but s.251(2)/s.145(3) substantive additions set aside; s.12AA cancellation not sustained in appeal

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ITAT upheld the validity of reopening under s.148 (reasons recorded, sanction obtained, survey-linked information), dismissing the challenge to jurisdiction and the plea for s.153C. However, the Tribunal allowed the appeal on substantive additions: it held that CIT(A) wrongly exercised powers under s.251(2) read with s.145(3) without applying accepted accounting/project completion methods, rendering those additions bad in law; consequential disallowances and construction-expense additions sustained by AO/CIT(A) were deleted. The cancellation of registration under s.12AA and related presumptive additions were not sustained, and the impugned additions are set aside in favour of the assessee.....