Reopening Quashed for Mechanical “Bogus Sub-Contractor” Reasons

Jitendrakumar Dahyalal Parmar Vs ITO (ITAT Ahmedabad) Reopening Based on Identical “Bogus Sub-Contractor” Reasons Quashed; 44AD Income Cannot Be Re-Disallowed: ITAT Ahmedabad Summary: The Ahmedabad Bench (SMC) of the Income Tax Appellate Tribunal (ITAT) allowed the assessee’s appeal for AY 2011-12 and quashed the reassessment proceedings under section 147, holding that the reasons recorded for reopening were mechanical, identical, and without independent application of mind. The reassessment was initiated based on a search in the DRA Group, alleging that payments made to the assessee as ...