“Either…Or” Reasons Show AO’s Non-application of mind: ITAT Ahmedabad quashes Reopening

Shaival Comcon LLP Vs ITO (ITAT Ahmedabad) Assessee, was subjected to reassessment proceedings u/s 147 on the basis of information that it had not filed a return of income for AY 2017-18 &  had purchased immovable property worth ₹4.50 crore during the relevant financial year. AO issued notices but recorded no compliance from Assessee. Consequently,  assessment was completed ex-parte u/s 144 r.w.s. 147, with the entire amount of ₹4.50 crore treated as unexplained investment u/s 69, taxable at the rate prescribed u/s 115BBE. In appeal, the assessee contended it had in fact filed its re...