ITAT Delhi Quashed Reassessments for Wrong Reasons, Time-Bar & Invalid Sanction

DCIT Vs Interlink Foods Private Ltd. (ITAT Delhi) The appeals filed by the Revenue & cross-objections by Interlink Foods Pvt. Ltd. were heard together since they involved common issues. For AY 2011-12, Assessee challenged reopening u/s 147 based on incorrect reasons—AO had recorded that Assessee took accommodation entries from Surendra Kumar Jain of RKG Finvest Pvt. Ltd., but later admitted this was a “typographical mistake” & proceeded against other entities (Twinkle Mercantile Pvt. Ltd. & Shalini Holding Pvt. Ltd.). Tribunal held that such substitution of reasons is impermi...