Reopening Collapses on Wrong Facts: ITAT Ranchi Quashes Section 148 Notice in Share Capital Case

Saluja Steel and Power Pvt. Ltd Vs ACIT (ITAT Ranchi) The ITAT Ranchi quashed the reassessment for AY 2013–14, holding that the reasons recorded for reopening were fundamentally flawed and factually incorrect. The assessee’s original assessment had been completed under section 143(3) after detailed scrutiny of share application money and share premium, including issuance of notices under section 142(1) and summons under section 131 to share applicants, whose directors had appeared and furnished details. Post-search, the AO issued notice under section 148 based on an investigation report al...