Additions in Reassessment Proceedings not Sustainable If no Addition on Primary Grounds

Shri Satyawan Vs ITO (ITAT Delhi) Hon’ble Delhi High Court considering the decision of the Hon’ble Bombay High Court in the case of CIT Vs. M/s. Jet Airways (I) Limited (2011) 331 ITR 236 (Bom.) held that if the Assessing Officer does not make any addition on the primary ground on the basis of which proceedings under Section 147 were initiated he cannot make other additions. The ratio of the decision of the Hon’ble Delhi High Court squarely applies to the facts of the case since the Assessing Officer did not make any addition for which the reopening was made. The Assessing Officer made v...