ITAT Quashes Reassessment for Shifting Allegation from Shares to Bogus Purchases

Shalini Chhabra Vs ITO (ITAT Delhi) Change of Goalpost’ Fatal to Reassessment: ITAT Quashes Reopening Where Allegation Shifted from Share Investment to Bogus Purchases The Delhi ITAT allowed the assessee’s appeal and quashed the reassessment for AY 2018-19, holding that the entire reopening was vitiated due to a fundamental change in the basis of proceedings. Initially, the notice under Section 148A(b) alleged that the assessee had made unexplained investment in equity shares of ₹86.73 lakh. However, in the order under Section 148A(d) and the final reassessment order, the allegation was ...