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AO Quoted Non-Existent Section 147(a) -ITAT Quashes Reassessment
Case Law Details
- Case Name
- Jaivir Vs ITO (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2012-13
- Courts
- All ITAT, ITAT Delhi
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Jaivir Vs ITO (ITAT Delhi)
AO’s Reliance on Repealed Law Costs Revenue Dear – Reopening Without Application of Mind Invalid:
Facts:
No return originally filed for AY 2012-13.
AO received information of cash deposits ₹17.40 lakh in Punjab National Bank during FY 2011-12.
Notice u/s 148 issued (29.03.2019) with prior approval u/s 151.
Assessee filed return on 29.10.2019, explained deposits as sale proceeds of agricultural land.
AO rejected explanation, added ₹17.40 lakh u/s 69A as unexplained cash deposits; also added bank interest ₹44,782 & disallowed deduction u/s VIA.
CIT(A...
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