ITAT Allows Appeal Because Cross-Examination of Key Witnesses Was Denied

Rajendra Prasad Choudhary Vs ACIT (ITAT Jaipur) The Jaipur ITAT allowed the assessee’s appeals for Assessment Years 2012-13 and 2013-14, holding that the reassessment proceedings initiated under Section 147 were invalid as they were based on borrowed satisfaction rather than the Assessing Officer’s independent application of mind. The Tribunal also found violation of principles of natural justice due to denial of cross-examination and observed that the additions were unsustainable even on merits. The assessee’s case was reopened on the basis of information received from the DGIT (Investi...