Audit Objection-Driven Reopening Invalid Without AO’s Satisfaction: ITAT Ahmedabad

Rajkamal Agro Industries Vs ITO (ITAT Ahmedabad) ITAT Ahmedabad Quashes Reassessment Based Solely on Audit Objection: No Independent Application of Mind by AO The Ahmedabad Bench (SMC) of the ITAT allowed the assessee’s appeal for AY 2015-16 by quashing the reassessment proceedings initiated under section 147. The Tribunal held that the reopening was based entirely on audit objections and reflected borrowed satisfaction, without any independent application of mind by the Assessing Officer. On the first issue of alleged excess depreciation due to capital subsidy, the Tribunal noted that the s...