Share capital accepted in scrutiny assessment cannot be added in Assessment U/s. 153A

ACIT Vs SMC Power Generation Ltd. (ITAT Delhi) ITAT held that assessment was earlier completed u/s 143(3) wherein the share capital had been scrutinized and accepted by the revenue, holding the same share capital as unexplained in the present reassessment u/s 153A tantamounts to change of opinion not backed by any evidence and, therefore, not legally sustainable. FULL TEXT OF THE ITAT JUDGEMENT Challenging the order dated 24.3.2015 in Appeal No.98/14-15 passed by the learned Commissioner of Income-tax(Appeals)-23, New Delhi {for short “ld. CIT(A)}, revenue preferred the appeal whereas asses...