AO Quoted Non-Existent Section 147(a) -ITAT Quashes Reassessment

Jaivir Vs ITO (ITAT Delhi) AO’s Reliance on Repealed Law Costs Revenue Dear – Reopening Without Application of Mind Invalid: Facts: No return originally filed for AY 2012-13.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...