Enhancement by CIT(A) on an issue which were not part of reasons recorded for reopening the assessment are invalid

Harendra Singh Vs ITO (ITAT Delhi) CIT(A) while deleting the sole foundational issue on which the re-assessment proceedings were initiated, cannot go further and examine an issue which was not even the subject matter of re-assessment proceedings Since the reopening was to verify the purchase transaction and since the said transaction never took place and, therefore, the addition made by the AO was deleted by the CIT(A). Therefore, CIT(A) had no power to enhance the assessment on an altogether different issue which was never there in the reasons recorded for reopening the assessment. FULL TEXT ...