Subhash Runwal v. ITO (2024) 232 TTJ 99/ 243 DTR 177 / 38 NYPTTJ 1252 (SMC) (Pune)(Trib)

S. 147: Reassessment-Cash deposits-No addition was made in respect of reasons recorded-Issue which is not subject of recorded reason-Addition cannot be made-Additional ground is admitted.[S. 148, 254(1)]

Held that if the AO initially has a reason to believe that certain income has escaped assessment, which in fact did not escape assessment owing to operation of provisions of cl. (b) of sub-s. (1) of s. 139, additional grounds are not available to the Revenue for making additions of any other income which did not find place in the s. 148 notice issued to the assessee. Addition is deleted.  (AY. 2012-13)

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