Additions Cannot Survive When Reassessment Is Quashed by High Court – Revenue’s Appeal Dismissed

DCIT Vs Oasys Cybernetics Pvt. Ltd (ITAT Chennai) The assessee, a company engaged in system integration business, filed its return for AY 2016-17 declaring nil income. The assessment was originally completed u/s 143(3) on 28-12-2018 wherein income was estimated at 8% of gross receipts. Subsequently, the AO reopened the assessment by issuing notice u/s 148 dated 26-03-2021 and completed reassessment u/s 147 on 31-03-2022 making additions including disallowance of depreciation on intangible assets (₹8.93 crore) and disallowance of delayed employees’ PF/ESI contribution (₹0.52 crore). The a...