Reopening Based on Internal Audit Memo Unsustainable Before Section 148 Amendment: ITAT Mumbai

ACIT Vs Rishabh Diamond Pvt Ltd. (ITAT Mumbai)

ITAT Mumbai held that the internal audit memo is outside the scope and ambit of the term “information” as provided in Explanation 1 to section 148 of the Act, prior to its amendment by the Finance Act, 2022. Accordingly, reopening of proceedings liable to be quashed.

Facts- Revenue has preferred the present appeal mainly contesting that the CIT(A) erred in not considering the amendment of Explanation 1 (ii) of section 148 of the Income Tax Act with effect from 01.04.2022 which specifies any audit objection a

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