Section 54F Disallowance Invalid When Not Part of Reopening Reasons

Devi Manubhai Shah Vs ITO (ITAT Mumbai) Reassessment Quashed Where Only Addition Was Beyond Recorded Reasons — Section 54F Denial Invalid The Mumbai Bench of the ITAT allowed the assessee’s appeal for AY 2012-13, holding that reassessment proceedings fail when the Assessing Officer makes no addition on the issues recorded for reopening and sustains the assessment solely on an unrelated ground. In this case, reassessment under section 147 was initiated based on alleged irregularities in investments and buyback of shares. However, while completing the reassessment, the AO made only one addit...