Dismissing the appeal of the revenue the Court held that the Tribunal had relied on judicial precedents to hold that once the principal grounds on which reassessment under section 147 was proposed were dropped, no further additions could be made even by taking recourse to Explanation 3. Its order deleting the additions made under section 68 was affirmed.(AY. 2011-12)
PCIT v. Jaguar Buildcon Pvt. Ltd (2025) 479 ITR 345 (Delhi)(HC)
S. 147 : Reassessment-Cash credits-Accommodation entries-Addition made on different grounds not forming part of reasons for reopening of assessment-Once principal grounds on which reassessment was proposed are dropped, no further additions can be made even by taking recourse to Explanation 3 to section 147-Order of Tribunal deleting the addition is affirmed. [S.68, 147, Expln. 3 148, 260A]
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