No Firm, No Assessment: ITAT Mumbai Strikes Down 147 on Dissolved Partnership

Manilal P. Savla & Company ACIT (ITAT Pune) The appeals concerned a dissolved partnership firm M/s Manilal P. Savla & Company, which had ceased to exist after 31.08.2012. Despite the dissolution being duly intimated to the Department in 2013, the AO reopened AY 2017-18 on the basis of a third-party search statement of one Shri Sachin M. Nahar, who allegedly stated that the firm had given cash loans of Rs.56,50,000. Relying solely on this statement & without supplying a copy to the Assessee, AO made an addition u/s 69A r.w.s. 115BBE & completed assessment u/s 147 r.w.s. 144 on a...