Tribunal Rejects Reopening Triggered by Irrelevant Information

Dream Infrastructure Vs ITO (ITAT Rajkot) AY 2013-14 Reasons Used for AY 2011-12; Wrong-Year Reasons = Wrong Jurisdiction: Only Right Year, Right Reasons – ITAT Quashes Reopening for AY 2011-12 Assessee’s case was reopened u/s 147 based on information about alleged cash payment of Rs.8,00,000 to Shri Jawahar Mori found in loose sheets seized during survey. AO issued notice u/s 148 on 26.03.2018 & completed reassessment u/s 143(3) r.w.s.147 on 27.12.2018 treating the amount as income from undisclosed sources. CIT(A) upheld reopening & sustained addition relying on alleged incons...