ITAT Guwahati Quashes Reassessment Notice, Treats Loose Sheets as Dumb Documents, Deletes Protective Sec 69C Addition

ACIT Vs DS Systems Private Limited (ITAT Guwahati) Reassessment Notice Held Invalid & Loose Sheets Treated as Dumb Documents – Protective Addition U/s 69C Deleted – ITAT Guwahati ITAT dismissed Revenue’s appeal and upheld CIT(A)’s order deleting protective addition of ₹3.25 crore u/s 69C alleged as unexplained cash payment. Tribunal noted that the reassessment notice issued on 29.06.2021 was invalid as AO failed to follow amended sec.148 procedure and CBDT Instruction No.1/2022 pursuant to Ashish Agarwal ruling, thereby vitiating the entire reassessment. On merits also, t...