Reassessment Beyond Four Years Invalid Without New Evidence: ITAT Chennai

Agni Steels Pvt. Ltd. Vs DCIT (ITAT Chennai) Audit Objection is not Tangible Material – Reopening Without Fresh Evidence is Review in Disguise – ITAT Chennai Quashes 147 Assessee engaged in manufacture of TMT bars, appealed against order of CIT(A)- for AY 2014-15. appeal, though delayed by 217 days, was admitted as Tribunal found sufficient cause for condonation. Dispute arose from reopening of assessment u/s 147. Originally, assessment was completed u/s 143(3) on 18.12.2017, wherein deduction u/s 80IA was partly disallowed. Subsequently, AO issued notice u/s 148 on 31.03.2021 (i.e., after...