Kapadia Money Changers (P.) Ltd. v. ACIT (2019) 266 Taxman 160/(2020)423 ITR 633 (Guj) (HC)

S. 147 :Reassessment -Salaries paid to employees – Reconciliation statement was filed – Reassessment proceedings was quashed .[ S.37(1), 148 ]

Assessment was completed u/s 143 (3). AO initiated reassessment proceedings on ground that assessee had debited higher amount of salaries paid to employees in profit and loss account as against actual payment of salaries mentioned in salary register, in view of fact that assessee had submitted all relevant facts in respect of salary expenditure at time of completing assessment and, moreover, assessee had also filed a reconciliation statement showing that amount paid as per salary registers was same as debited in profit and loss account. On writ the reassessment was quashed . (AY. 2011-12)