Additions in reopened Assessment not valid if no addition on subject matter of reopening

Sheela Foam Ltd. Vs DCIT (ITAT Delhi)

The issue under consideration is whether the re-opening of assessment is valid even if there is no addition on subject-matter being basis for issuing notice under section 148, rather AO made addition on other counts?

ITAT states that, applying the principle laid down by the Hon’ble Bombay High Court in Jet Airways (I) Ltd.(supra) and Hon’ble Delhi High Court in Ranbaxy Laboratories Ltd. vs CIT (supra), they hold that in the facts a

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