Reassessment Quashed as AO Taxed Capital Gains Instead of Recorded Escapement Issue

Ichchaben Kantilal Desai Vs ITO (ITAT Surat) The ITAT Surat held that a reassessment under Section 147 cannot survive when the Assessing Officer (AO) ultimately makes additions on issues completely unrelated to the reasons recorded for reopening. In this case, the reassessment was initiated solely on the basis of alleged unexplained time deposits of ₹10 lakh and interest income of ₹24,329. However, during reassessment proceedings, the AO instead made a substantial addition of ₹24,62,107 towards long-term capital gains (LTCG) arising from the sale of ancestral land, along with an addition...