Reopening under 147 invalid where recorded reason not pursued- ITAT Kolkata

DCIT Vs SRMB Srijan Private Limited (ITAT Kolkata) Kolkata Tribunal  dismissed Revenue’s appeal & upheld the CIT(A)’s order quashing reassessment initiated u/s 147, holding that reopening cannot be sustained when the recorded reason for escapement was not pursued in assessment. Assessee filed return on 24.09.2011 declaring income of ₹5.00 crore. Assessment was completed u/s 143(3) on 24.03.2014. AO later reopened u/s 147 on 28.03.2018 on the ground that commodity profit of ₹1.61 crore had escaped assessment. However, in reassessment order u/s 147 dated 22.01.2018, AO made no add...