Reopening Fails When AO Taxes a Different Income Than the One Recorded in Reasons

Manish Vij Vs ACIT (ITAT Delhi) The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) considered an appeal for Assessment Year 2015-16 arising from an assessment completed under Section 147 of the Income-tax Act. The primary issue concerned the validity of reassessment proceedings initiated under Sections 147 and 148 and the subsequent addition made by the Assessing Officer. The assessee challenged the reopening on the ground that the reassessment was initiated based on an allegation that the assessee had acted as an “exit provider” in alleged accommodation entry transactions involvi...