No Reopening for Fishing & Roving Enquiries: ITAT Invalidates Section 147 Proceedings

Ambica Timber Trade Pvt Ltd Vs ITO (ITAT Delhi) The Delhi ITAT partly allowed the assessee’s appeal for AY 2012-13 by quashing reassessment proceedings initiated under Section 147 of the Income-tax Act, 1961. The assessee had challenged both the validity of the reassessment and the addition of Rs. 7,39,62,714 on merits. Since the issue of jurisdiction was fundamental, the Tribunal examined it first. The reassessment was initiated based on information received from the Investigation Wing, Gurgaon, alleging that the assessee had received accommodation entries amounting to Rs. 7,39,62,714 f...