Protective additions without substantive foundation quashed – ITAT Visakhapatnam invalidates reopening based on suspicion

ACIT Vs Vijayasai Lakshmi Srinivasa Cotton Mills (ITAT Visakhapatnam)

Revenue had filed four separate appeals against the common orders of CIT(A), deleting protective additions made in reassessment proceedings for the assessees – Vijayasai Lakshmi Srinivasa Cotton Mills, Madhusudhana Venkata Subba Rao Potti, Potti Kumara Naga Venkata Sai Chakravarthy & Shivani Cotton Industries Pvt Ltd., all of Guntur. These additions had originated from a common search conducted in the case of Jaya Balajee Real Media Pvt Ltd (JBRMPL), a film-production company, which had deposited about

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