ITAT Surat: 263 Orders Passed Just to ‘Keep Issue Alive’ Set Aside for Fresh Adjudication

Sachin Notified Area Vs PCIT (TAT Surat) Background SNA, constituted under Gujarat Industrial Development Act (GIDA), filed NIL returns claiming exemption u/s 10(20). Reassessments completed u/s 147 r.w.s. 144B on 30.03.2022, denying exemption following SC ruling in NOIDA vs. CCIT (95 taxmann.com 58). AO accepted treatment of FDR interest ₹9.16 Cr directly credited to reserves in balance sheet, without routing through I&E a/c PCIT held AO erred in not taxing interest under “income from other sources” & issued 263 orders. Assessee argued identical 263 order for AY 2017-18 had bee...