AO’s Own Penalty Order Sinks Reassessment: ITAT Holds First Section 147 Order ‘Infructuous’

ASL Capital Holdings Pvt. Ltd. Vs ACIT (ITAT Mumbai) AO’s Own Penalty Order Sinks Reassessment: ITAT Holds First Section 147 Order ‘Infructuous’ The Mumbai ITAT quashed a reassessment by holding that there cannot be two reassessment orders for the same assessment year, same transaction and same addition. The case involved alleged bogus penny stock transactions in shares of Sunstar Realty Development Ltd., where the AO had first reopened the assessment under the old reassessment regime and passed an order under Section 147 making an addition of ₹2.34 crore. Subsequently, after the Supre...