Dismissing the appeal of the revenue the Tribunal held that when no addition was made in respect of recorded reason for which the notice u/s 148 was issued, the Assessing Officer cannot make any other addition. (AY. 2008-09, 2009-10)
ACIT(E) v. Everest Education Society. (2021) 188 ITD 8 (Pune)(Trib.)
S. 147 : Reassessment-Anonymous donation-Notice for under utilisation of income-No addition was made in respect of notice issued-Addition made on account of anonymous donation is held to be without jurisdiction and bad in law. [S. 115BBC, 148]