Additions on grounds not forming part of reasons for reopening assessment not sustainable if no addition based on reason for reopening

Indian Redcross Society Vs ITO (ITAT Ahmedabad)

We note that the Ld. Assessing Officer has not made any additions and nor even discussed the issue on the basis of which the reassessment proceedings were initiated. The assessee had pointed out that the Ld. Assessing Officer had committed a factual inaccuracy by stating that a sum of Rs. 89,60,505/- was deposited in the bank account, whereas total cash deposits in the bank account held by the assessee were to the tune of Rs. 29,85,834/-only and this fact has not been controverted either by the Ld. Assessi

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