Rectification u/s 154 on Dropped Reopening Held Invalid – ITAT Delhi Quashes ₹3.56 Cr Addition

Baani Landbase Pvt. Ltd. Vs DCIT (ITAT Delhi) Assessee’s assessment u/s 143(3) was completed on 28.12.2017, showing loss of ₹2.04 crore. Later, AO issued notice u/s 148 (30.06.2021) to reopen on the ground that provision for construction expenses ₹9.25 crore & deduction of ₹3.56 crore allowed in the next year had escaped assessment. However, the reopening was dropped on 30.07.2022, as AO himself concluded that the issue did not fall within the meaning of “asset” & hence not a fit case for reassessment. Subsequently, AO invoked section 154 to “rectify” the same issue, tr...